Against the background of Russia’s war of aggression against Ukraine, the European Union has imposed a number of sanctions on Russia. Some of the sanctions are aimed directly at individuals or commercial companies. In order to be able to implement these more effectively, a sanctions enforcement law has been in force since May of this year, which also makes logistics companies responsible.

Logistics companies have to be particularly careful in these times: While forwarders – especially those who do business with Russia – have to be careful not to transport sanctioned goods, the Sanctions Enforcement Act added another task:

Registration register according to § 23a AWG

The law obliges logistics service providers to report customers whose assets are being sanctioned. This must be done as soon as the logistic company is aware of it. The transport of the goods as well as the acceptance of the order are punishable. The Federal Office of Economics and Export Control provides a corresponding registration form.

Private individuals or companies affected by the embargo can be reported here.


Our recommendations for action for freight forwarders:


– Find out regularly about applicable embargoes

– The notification obligation for logistics service providers applies to those who fall under Sections 453 and 467 of the Commercial Code. So first check if your service is affected.

– Check if business partners are subject to sanctions – if so, report it and close the deals.

– Train your staff accordingly.


Source: Federal Office of Economics and Export Control (German version only)