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Sanctions and Dual-Use Screening

We screen your business partners, destination countries, goods and end uses against EU sanctions lists and Dual-Use Regulation 2021/821, classify Annex I entries and apply for BAFA export licences on your behalf. You send us consignee master data and product description — you receive a sanctions-check report, classification result and licence documentation, so shipments clear customs on time and penalties stay off the table.

What it is about

We manage two tightly linked compliance tracks in your foreign trade operations: we screen your business partners against EU sanctions lists (country- and sector-based, directly applicable across the EU) and we classify your goods as dual-use where required (civil items with military potential, subject to licence under Regulation 2021/821). You give us consignee, product and end use — we screen, document and hold the shipment before delivery bans, fines or criminal proceedings apply.

Legal framework and 2026 status

  • EU Dual-Use Regulation (EU) 2021/821 of 20 May 2021, governs export, brokering, technical assistance, transit and transhipment of dual-use items.
  • EU sanctions regulations, country- and topic-specific, with direct applicability in all EU Member States.
  • Russia sanctions: Regulation (EU) 833/2014, continuously tightened. Current status 2026: 15th sanctions package (16 December 2024), 16th sanctions package (24 February 2025), 17th sanctions package (20 May 2025), 18th sanctions package (18 July 2025).
  • Belarus sanctions: Regulation (EU) 765/2006 as amended.
  • German Foreign Trade Act (AWG) and Foreign Trade Ordinance (AWV) - national specification in Germany.
  • Competent authority for licences and rulings: BAFA (Federal Office for Economic Affairs and Export Control).

Current EU sanctions packages against Russia (Q2 2026 status)

  • 15th sanctions package (16 December 2024): expansion of the lists of sanctioned persons and vessels (shadow fleet), additional restrictions on drone components and chemicals.
  • 16th sanctions package (24 February 2025): aluminium import ban, further shadow-fleet listings, stricter no-Russia clause requirements.
  • 17th sanctions package (20 May 2025): additional shadow-fleet listings, further export and import restrictions, tightening of circumvention provisions.
  • 18th sanctions package (18 July 2025): expansion of restrictive measures, additional listings and sectoral tightenings.
  • Continuing: import bans for oil, coal, gold, iron/steel products from Russia.
  • Export bans for dual-use items, high tech, luxury goods, certain machinery.
  • No-Russia clause: mandatory contractual re-export restriction in non-EU country contracts.

Dual-Use Regulation 2021/821

We classify your goods against Annex I of Regulation 2021/821 — around 2,000 list entries with technical thresholds for high-performance computers, encryption technology, machine tools, sensors and chemicals. You send us the data sheet and end use; we assign the entry (e.g. 1A001, 5A002) and confirm whether your export requires a licence.

  • Annex I: EU dual-use list with export list entries (format e.g. 1A001, 5A002).
  • Annex II: EU general authorisations (e.g. EU001 for certain destination countries).
  • Annex IV: especially sensitive dual-use items with additional controls.
  • Catch-all clause (Art. 4): authorisation requirement also for non-listed items if military end use in a sanctioned country is known.
  • Brokering, technical assistance and transhipment can also be subject to authorisation.

Screening obligations

  • Business-partner screening: matching customers, suppliers, carriers and end users against the EU financial sanctions list, UN lists and US OFAC lists.
  • Goods screening: reconciling technical specifications with Annex I of the Dual-Use Regulation and Annex VII (Russia-specific items).
  • Country / end-use screening: review of destination country, end use and end user.
  • Obligation to repeat screening on contract amendments, partner changes or new sanctions packages.

BAFA licences

  • Individual licence: for a specific consignment to a defined consignee, with conditions.
  • Collective licence: for several consignments to recurring consignees, with reporting obligations.
  • Maximum value licence: above a certain value for a defined period.
  • General licences (AGG/EU-AGG): for certain goods and destination countries under standardised conditions; registration with BAFA required.
  • Application via the electronic application, delivery and information system (ELAN-K2) of BAFA.

Obligations in the customs declaration

  • Entry of the export list position (e.g. 5A002a) in the export declaration (ATLAS-Export).
  • Entry of the BAFA licence number and use of licence codes.
  • Customs review for completeness and plausibility; clarification with BAFA in case of issues.
  • Infringements can trigger sanctions proceedings under AWG (fines, custodial sentence of up to 5 or 10 years in particularly serious cases).

Typical risks

  • Delivery to listed persons or organisations despite a formally valid contract.
  • Export of dual-use items without licence due to insufficient technical classification.
  • Circumvention of sanctions via third countries (so-called diversion risk).
  • Missing or patchy documentation of the screening processes, with negative consequences in BAFA or customs audits.
  • Late reaction to new sanctions packages - existing contracts can become non-compliant overnight.

How we support you

  • Early warning in the customs process: detection of sanctions and dual-use indicators in import and export clearance.
  • Screening of consignee and supplier master data against sanctions lists.
  • Support with classification of goods under Annex I of the Dual-Use Regulation.
  • Support with BAFA applications and clarification of conditions.
  • Training of sales, procurement and logistics on current sanctions packages.
Request export control advice Talk to us: 02828 9039920

Frequently asked questions

We run both tracks in parallel: sanctions target the consignee — persons, organisations, countries, sectors (e.g. Russia packages 17/18). Dual-use targets the goods — civil items with military potential (high-performance computers, encryption technology), subject to licence even outside sanctioned countries. You give us consignee and product details; we run both checks and deliver a combined result.
You remain responsible as exporter — we carry out the classification on your behalf. You send us the data sheet and manufacturer specification; we match it against Annex I of Regulation 2021/821 and, on borderline cases, we obtain a BAFA goods-list ruling. For highly technical cases we engage a subject-matter expert and keep you informed throughout.
We plan for four to twelve weeks for individual licences, and longer for sensitive destination countries. You provide us with the required documents; we prepare the application, file it via ELAN-K2 and track the deadline. For AGG/EU-AGG we handle the BAFA registration — the licence is usable immediately once granted.
Since the 12th sanctions package (December 2023), contracts with non-EU counterparties must contractually prohibit re-export of Annex XXXIII goods (high tech, machine tools, drone components) to Russia. We screen your shipment against Annex XXXIII and tell you whether the clause is required — drafting the clause is for your legal team, not us.
Under AWG, infringements carry fines or custodial sentences of up to five years — in particularly serious cases up to ten years — plus administrative penalties, withdrawal of authorisations, entry in the German Trade Register and reputational damage. That is precisely why we identify and stop risky shipments before the customs declaration, not after seizure.
You send us consignee master data (company name, address, UBO if known); we screen against the EU financial sanctions list, UN lists and US OFAC and return a documented screening report — before contract conclusion and after every new sanctions package. We archive each check in a traceable format so you can produce the report instantly in any BAFA or customs audit.