EU sanctions apply within the territory of the EU, including in Germany.  EU sanctions also apply to any individual who is a national of an EU Member State, whether inside or outside the EU.  EU sanctions also apply to any legal person, entity, or body incorporated or otherwise constituted under the laws of an EU Member State, including in Germany, whether operating inside or outside the EU.  Finally, EU sanctions also apply to any legal person, entity, or body with respect to any business conducted, in whole or in part, within the EU.

Particular attention should be paid to the criterion of “any business done in whole or in part within the EU”, which can, in certain circumstances, create a long-arm jurisdiction effect bringing what might otherwise be entirely non-EU transactions under the scope of EU sanctions if there is a partial EU nexus.  In practice, any party or transaction with any EU nexus as outlined above is subject to the EU sanctions regime, whereas German parent companies are expected to exercise their influence to their non-EU subsidiaries to the extend permissible by applicable local law to avoid circumvention of EU sanctions.  For more information, see the EU restrictive measures.

German export controls apply to natural and legal persons in Germany and, in defined circumstances, to Germans and EU residents abroad.  They attach to exports, intra‑EU transfers of certain items, brokering, technical assistance, and transit, and they also implement embargoes and sanctions that prohibit or license-restrict dealings with certain destinations, end uses, and end users.  In short, anyone resident or established in Germany, anyone exporting or transmitting controlled software/technology from Germany, any broker or provider of technical assistance resident or established in the EU, and Germans abroad in specified cases will be covered.