The most frequently asked questions about the sanctions list

The most common questions about the sanctions list include:

What is a sanctions list?
Why do you have to check against sanction lists?
Who has to check against sanction lists?
When do sanctions lists have to be checked?
How often do sanctions lists have to be checked?
Which sanctions lists have to be checked?

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For instructions on sanctions list checks

What is a sanctions list?

A sanctions list is a publicly accessible list of persons, associations or companies against which economic and / or legal restrictions have been issued by states or communities of states. In some cases, the lists of goods are also counted among the sanction lists, which in turn prohibit the delivery of certain goods to named persons and / or states.

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Why do you have to check against sanction lists?

A start was made with the examination of persons suspected of terrorism in response to the attacks of September 11, 2001. The legal basis for this in the EU are the regulations:

There are also other general or country-specific EU embargo regulations, which list persons and organizations in the appendices for which restrictions exist. There are currently export restrictions for certain goods, especially against institutions in Iran, North Korea, South Sudan, Russia and Ukraine. According to Section 4 (2) of the German Foreign Trade Act (AWG), the obligations to act resulting from the resolutions of the Council of the European Union must be implemented. In the event of a violation, there is a risk of up to 10 years imprisonment and heavy fines for managing directors and those responsible for export.

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Who has to check against sanction lists?

Every resident or economically active company in the EU is obliged to do so in accordance with the applicable EU regulations and the AWG and to operate a technically justifiable effort, all business partners against the published European list Common Foreign & amp; Check Security Policy (CFSP). This means that not only exporting companies but also companies that only do business in Germany have to check all business partners, suppliers, customers and employees against the sanction list.

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When do sanctions lists have to be checked?

Even if your company only does business within Germany, the management is obliged to check whether the business partner is on a sanctions list or an anti-terror list. In this case, this contact must not receive any economic resources or financial support. Failure to do so can result in fines and imprisonment. First and foremost, the company is liable, the people affected are almost always the managers and, under certain circumstances, the export manager. In addition, there are specific economic risks, particularly in connection with the US lists. For example, if an employee or the company is listed on the SDN list just because it is legal according to German Right has business relationships with Iran, this can mean that the company is no longer supplied by American manufacturers.

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