# Sanctions screening for small companies in Germany

By Rotomal team · Updated 2026-11-07 · Part of [Listenwache](https://rotomal.com/en/sanktionslistenpruefung/)

**Short answer:** EU sanctions regulations forbid every company in the EU from making funds or economic resources available, directly or indirectly, to listed persons and entities; the law leaves open how you ensure this. Intentional breaches carry three months to five years in prison under § 18 AWG, negligent ones are administrative offences with fines up to €500,000 under § 19 AWG. The usual approach is a documented screening of all business partners, before the first deal and regularly afterwards, because the lists change constantly.

## Which lists exist

| List | Publisher | Access |
| --- | --- | --- |
| EU consolidated financial sanctions list | European Commission (DG FISMA) | Open data; the EU Official Journal is binding |
| UK Sanctions List | UK government | CSV, XML, ODS and online search; the only UK list since 28 January 2026 |
| US Consolidated Screening List | US Departments of Commerce, State and Treasury | Free search, CSV, JSON and API |
| finanz-sanktionsliste.de | German federal and state justice portal | Search based on the EU list, aimed mainly at the judiciary |

The EU itself notes that its consolidated list may lag behind the Official Journal. On 7 November 2026, finanz-sanktionsliste.de showed 23 October 2026 as its data date.

## Penalties for breaches

| Provision | Offence | Range |
| --- | --- | --- |
| § 18(1) AWG | Intentional breach of making-available or disposal bans | 3 months to 5 years in prison, attempts punishable |
| § 19(1) and (6) AWG | Negligent breach | Fine up to €500,000 |
| § 19(7) and (8) AWG | Corporate fine (§ 30 OWiG) for an intentional offence under § 18(1) or a supervisory failure (§ 130 OWiG) | Up to €40 million |

## A lean procedure in five steps

- Keep all customers and suppliers in one list with name, address and country.
- Screen against the EU list before the first deal, and against UK and US lists where relevant.
- Rescreen the whole base regularly, because listings are added constantly.
- Review possible matches using date of birth, registration number, country and address, and record the reason.
- On a real match, pause the deal and involve the competent authority or a lawyer; in Germany the Deutsche Bundesbank handles financial sanctions.

## If you would rather hand it off

Listenwache does the screening, review and log from €39 a month, and the first screening of 100 partners costs €9. It does not replace your own responsibility and is not legal advice; clarify your specific duties with the competent authority or a lawyer.

## FAQ

### Is one check when the contract is signed enough?

Usually not. The lists are updated constantly and a partner can be listed after you sign. That is why companies rescreen their base regularly.

### Is the OFSI list still valid?

No. The OFSI Consolidated List closed on 28 January 2026 and is no longer updated. The UK Sanctions List is the reference since then.

## Sources

- Gesetze im Internet: § 18 AWG https://www.gesetze-im-internet.de/awg_2013/__18.html
- Gesetze im Internet: § 19 AWG https://www.gesetze-im-internet.de/awg_2013/__19.html
- IHK Frankfurt am Main: financial sanctions https://www.frankfurt-main.ihk.de/international/importkontrolle-in-der-praxis/finanzsanktionen-5551694
- data.europa.eu: EU consolidated financial sanctions list https://data.europa.eu/data/datasets/consolidated-list-of-persons-groups-and-entities-subject-to-eu-financial-sanctions
- GOV.UK: The UK Sanctions List https://www.gov.uk/government/publications/the-uk-sanctions-list
- trade.gov: Consolidated Screening List https://www.trade.gov/consolidated-screening-list
- Justice portal: finanz-sanktionsliste.de https://www.finanz-sanktionsliste.de/

[Listenwache](https://rotomal.com/en/sanktionslistenpruefung/) does this for you. Request it free, no card: https://rotomal.com/en/sanktionslistenpruefung/request/
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Rotomal · https://rotomal.com/en/sanktionslistenpruefung/sanctions-screening-germany-sme/ · hello@rotomal.com