Foreign Trade and Sanctions

Foreign trade law and sanctions law affect export and import transactions, payment flows, services and data transfers. For internationally active companies, this creates ongoing obligations under national rules, EU sanctions and, depending on the business model, third-country regimes such as US sanctions (OFAC) and UK sanctions. Since the Russian invasion of Ukraine, EU sanctions compliance for designated persons and controlled goods has become even more operationally relevant.

We help you structure trade flows and supply chains in a compliant way. We support licensing and notification processes, reduce liability exposure and align your foreign trade compliance across functions (legal, compliance, procurement, logistics and finance). Where questions arise at short notice, we focus on clear decisions, documented risk assessments and workable controls.

Trade compliance experience across regulated sectors

Our clients include global industrial companies, distributors, logistics companies, technology groups and exporters of sensitive goods. We advise on trade compliance in day-to-day operations and in projects such as supply chain restructuring, market entries, internal investigations and M&A due diligence.

Core competences:

• The German Foreign Trade and Payments Act (AWG) and the German Foreign Trade and Payments Ordinance (AWV)
• EU sanctions regulations
• Export control, especially for dual-use goods
• The German War Weapons Control Act (KrWaffKontrG) and classification of goods
• Customs law, anti-dumping and anti-subsidy measures
• Capital and payment transactions with third countries
• WTO law and international trade barriers
• Compliance systems in foreign trade law

We combine legal analysis with an understanding of business processes, supply chains and financial flows. Where needed, we coordinate with the relevant authorities, including the Federal Office for Economic Affairs and Export Control (BAFA), the Central Office for Sanctions Enforcement (ZfS) and the Deutsche Bundesbank (German central bank). For multidisciplinary matters, we work with certified tax advisers, customs agents and compliance teams, and we coordinate with CMS partners on cross-border mandates.

Export control and sanctions services

• Reviewing EU sanctions measures and assessing restrictions affecting persons, goods and services
• Supporting export licences and other authorisation procedures under export control law
• Advising on reporting and notification obligations under foreign trade law and sanctions law
• Advising on national implementation measures for sanctions, in particular under the German Sanctions Enforcement Act (SanktDG)
• Preparing compliance documentation (e.g., certificates of conformity, end-use / final destination statements and internal requirements)
• Liaising with BAFA, customs authorities (including the ZfS) and the Deutsche Bundesbank in administrative processes
• Supporting foreign trade audits, inspections and investigative proceedings
• Advising on payment transactions and capital movements involving third countries
• Developing strategies to protect international supply chains and strengthen sanctions screening and trade compliance controls