EU sanctions law
As a German Rechtsanwalt with offices in Würzburg, Fürth and Moscow, I represent listed individuals and companies (in national and European authorisation procedures) as well as businesses with sanctions exposure, using the remedies EU law itself provides: delisting applications to the Council, actions for annulment before the EU General Court, applications for national licences, and more.
Everything on this page concerns either the remedies EU law itself provides or compliance with the sanctions and export-control rules in force. I do not advise on circumventing sanctions.
A request to review and remove a listing: analysis of the reasons the Council has communicated, access to the underlying file, preparation of counter-evidence and submissions to the Council, including in the context of the periodic review of the sanctions lists.
Challenging the listing act itself before the General Court of the European Union in Luxembourg. The time limit is two months from notification or publication plus the fixed extension on account of distance — checking that deadline is the first thing I do in any new matter.
Applications to the competent national authority — in Germany primarily the Deutsche Bundesbank — for authorisation to use frozen funds: for basic needs and living expenses, reasonable legal fees, taxes, insurance and account charges, and for contracts concluded before the listing, where the regulation provides for it.
For businesses: legal assessment of counterparties, goods and payments under the EU regulations and the dual-use rules, review of licensing obligations, internal procedures and how to deal with doubtful cases. The work is directed exclusively at complying with the restrictions in force.
Correspondence about frozen or blocked accounts, responses to requests for information, submissions and hearings before credit institutions, supervisory authorities and licensing bodies.
All legal work is carried out in strict compliance with current European legislation — in particular EU sanctions law — as well as the law of the Federal Republic of Germany, the Swiss Confederation and the Russian Federation.
The sequence is similar in every constellation, whether it ends in an application to the Council, a court action or a licence application.
Realistic timing: these matters usually run for several months, and proceedings before the EU General Court often take more than a year. No one can promise a duration or an outcome, and professional rules rightly forbid it.
Nothing has to be complete at the outset. The sooner the following items are available, the more reliable the first assessment will be.
Delisting is the removal of a person or entity from the annex to an EU sanctions regulation and the corresponding Council decision. Both listing and removal fall to the Council of the European Union, and the Member States have to agree. An application is therefore addressed to the Council, not to a German authority. Separately from that, the General Court of the European Union reviews the lawfulness of a listing when an action is brought.
The delisting application is an administrative route: the Council is asked to review and lift the listing. It is not bound by a strict deadline and can be renewed at each periodic review. The action for annulment under Art. 263 TFEU is court proceedings before the EU General Court, with a time limit of two months plus the extension on account of distance; the court examines whether the Council's statement of reasons holds up in fact and in law. The two do not exclude each other and are often combined.
The EU sanctions regulations contain exemptions of their own. On application, the competent national authority may authorise the use of frozen funds — for example for basic needs and living expenses, for reasonable professional fees and expenses of legal representation, for taxes, insurance premiums and account-maintenance charges, or for contracts concluded before the listing. This is a route the law itself provides, not a way around the measures: the application is reasoned, documented and decided by the authority.
Funds and economic resources are frozen: the account continues to exist, but no disposals are possible and no funds may be made available to the listed person. The bank reports the freeze to the competent authority. In practice this often extends to accounts of companies attributed to a listed person. Access to frozen funds normally comes only through a licence application or through removal from the list.
It depends on the remedy. A licence application to a national authority is often decided within a few months; a delisting application to the Council may span one or several review cycles; court proceedings before the EU General Court typically take from several months to more than a year. Anyone who names you a fixed period or promises an outcome cannot deliver on it.
Yes. These are written procedures, and being physically present in Würzburg or Luxembourg is not required for the conduct of the matter. Meetings take place by telephone or video, and documents are exchanged through a channel agreed in advance. I advise and correspond in English, German and Russian; the language of the case before the EU General Court is chosen when the action is brought, and annexes are translated accordingly.
For a first assessment, the listing act or the Council's notification with the statement of reasons is enough, together with a short account of the professional and corporate situation. Everything else — evidence, registry extracts, correspondence with banks — is collected in a structured way at the second stage. Please send confidential documents only after we have agreed on the transmission route.
I am a German-admitted Rechtsanwalt and personally advise on German and EU law. Where needed, I coordinate with locally admitted counsel. This gives you a single point of contact for cross-border matters — with clear lines of responsibility.
All legal work is carried out in strict compliance with current legislation — in particular EU sanctions law — as well as the law of the Federal Republic of Germany, the Swiss Confederation and the Russian Federation.
Your next step
Tell me briefly about your concern. Appointments are generally available within one week.
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This page provides general information and is not legal advice. A mandate arises only upon express engagement.