Background On 15 January 2026, the German Parliament adopted legislation transposing Directive (EU) 2024/1226, which defines and harmonizes criminal offenses and penalties for breaches of all EU restrictive measures (i.e., sanctions). The directive’s core provision, Article 3, sets out a comprehensive list of criminal offenses that cover most types of sanction violations. Transposing the directive into national law, Germany revised key provisions in sections 18 and 19 of the Foreign Trade and Payments Act (Außenwirtschaftsgesetz(AWG))…
On 8 September 2025, the EU Commission adopted a Delegated Regulation updating Annex I of the Regulation (EU) 2021/821 (“EU Dual-Use Regulation”). Although the changes have not yet entered into force, they outline the likely amendments to the EU Dual-Use Regulation. Background Annex I of the EU Dual-Use Regulation lists dual-use items that require export authorization pursuant to Article 3 paragraph 1 EU Dual-Use Regulation. Annex I is periodically amended, usually at least once a year, based on decisions…