Germany Tightens Sanctions Liability for Businesses: What Changed in 2026

The beginning of 2026 brought important changes for companies operating on international markets. On January 15, the German Bundestag adopted legislative amendments that significantly increase liability for violations of European Union sanctions. For businesses, this is a clear signal: foreign trade compliance has moved beyond formal reporting obligations into the realm of real legal risk.

The changes concern the rules governing foreign trade and compliance with EU restrictive measures. While many violations were previously treated mainly as administrative offences, some can now lead to criminal consequences. In other words, sanctions compliance is no longer just an internal formality — it is becoming a key element in protecting both the company and its management from serious government enforcement actions.

One of the most notable changes is the sharp increase in potential financial penalties. Possible fines for companies have risen substantially, and regulators are paying closer attention not only to the violation itself but also to how a company’s internal control system is structured. Insufficient internal oversight, a purely formal approach to screening business partners, or weak process documentation can now be viewed as independent compliance failures.

For many businesses, this means rethinking their overall risk management approach. Exporters, importers, logistics providers, financial institutions, and technology companies are particularly exposed. In practice, however, the new rules affect almost any business that interacts with foreign partners or cross-border supply chains.

Under the new framework, regular partner due diligence, clear internal guidelines for employees, and transparent decision-making processes for cross-border transactions become essential. Company leadership must not only introduce compliance procedures on paper but also be able to demonstrate that they work effectively in practice.

The January changes in German business law therefore represent more than a routine legislative update. They mark a shift toward a stricter model of foreign trade control, where corporate responsibility is significantly higher and the cost of compliance failures can be far more serious.