Insights

In-depth practical overview of EU transaction bans with state-linked entities (Annex XIX) and listed Russian ports/airports (Annex XLVII): scope, indirect transactions, key derogations and compliance steps.

Since 20 January 2025, 105 additional oil tankers of the so-called 'shadow fleet' have been listed under Regulation (EU) 2025/1494. Listed vessels are banned from EU ports and maritime services. Shipowners may challenge the listing before the General Court of the EU if the legal criteria under Article 3s(2) of Regulation (EU) No 833/2014 are not met. The deadline for filing an action is 13 October 2025.

When a sanctioned person brings an action before the General Court of the EU challenging a listing decision by the Council, a specific time limit must be observed. Legal advice from a qualified law firm is essential in delisting procedures.

When a sanctioned person dies, heirs face barriers accessing frozen assets. Learn how to request EU delisting or take legal action if the Council refuses.

The 17th sanctions package targets, among others, the Russian 'shadow fleet'. It includes ships/vessels that transport crude oil or petroleum products that originate in Russia or are exported from Russia while practicing irregular and high-risk shipping practices as set out in the International Maritime Organisation. Legal remedies for a removal from the sanctions list (delisting) are available. Contact a German/European attorney/lawyer.

The EU has implemented specific secondary sanctions, thereby extending its existing sanctions regime.

BGH rules on frozen securities: A German depository bank unlawfully restricted an Iranian bank's ownership rights.

A state liability claim due to a decision by a German stock exchange sanctions committee must be asserted against the federal state.

The EU Short Selling Regulation also applies to trading firms and investment funds located outside the EU/EEA (third-country firms).

Since 5 February 2025, the REMIT regulations (registration, insider trading, etc.) have also applied to wholesale hydrogen energy products.

Investment fund managers domiciled in the United Kingdom (UK) are generally permitted to market in Germany investment funds they manage.

Investment fund managers domiciled outside Germany must comply with specific regulations to market their investment fund in Germany.

BaFin's supervisory practice for granting license exemption for providing cross-border banking and financial services in Germany.

Originating loans in Germany generally requires a BaFin license, if the foreign investment manager cannot rely on a specific exemption.

German National Private Placement Regime (NPPR) provides rules for AIFM domiciled within and outside the EU/EEA that intend to market an AIF to German investors.

German REMIT representative for non-EU market participants: registration with Bundesnetzagentur/ACER (CEREMP), mandate & compliance under REMIT. Contact German law firm Kronsteyn.

Information on the legal background and what you can do, if your money or securities have been frozen by a German bank.

Gegen den Beschluss eines Sanktionsausschusses kann mit einer Frist von einem Monat Klage beim Verwaltungsgericht erhoben werden.

German DEHSt is the compentent authority for foreign aircraft operators in relation to the EU Emissions Trading System (EU ETS).

REMIT II integrated spot and derivative contracts for storage of electricity and natural gas into the concept of wholesale energy products.