• For EU Financial Sanctions, e.g., those based on Council Regulation (EU) 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, the authorities of the EU Member States for enforcing such EU Financial Sanctions (in Germany, the German Federal Bank) may authorize the release of certain frozen funds or economic resources, or the making available of certain funds or economic resources, after having determined that the funds or economic resources concerned are necessary to satisfy the basic needs of the sanctioned person or if the fund or economic resources concerned are intended exclusively for payment of reasonable professional fees or reimbursement of incurred expenses associated with the provision of legal services.
  • For EU economic sanctions, e.g., those based on Council Regulation (EU) 833/2014 concerning restrictive measures in view of Russia’s actions in destabilizing the situation in Ukraine, as amended, the competent authorities of the EU Member State to enforce such EU Economic Sanctions (in Germany, the BAFA) may authorize certain transactions, e.g., the sale of dual-use goods for nonmilitary use in Russia intended for maritime safety.
  • The German export control regime also includes exceptions and authorization requirements. A detailed description of the respective processes can be found here.
  • Finally, EU operators can seek authorization from the Commission to comply with laws blocked by the EU Blocking Statute in specific circumstances as an exemption from the rule.
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