A legal update published in today’s Bundesgesetzblatt has tightened Germany’s Residence Act (AufenthG). A new paragraph §14(3) flatly prohibits allowing entry or transit for any person named in an EU Council sanctions decision that blocks travel. Complementing the ban, a newly minted §95a introduces criminal penalties of three months to five years’ imprisonment for anyone who wilfully assists a listed person to cross Germany’s borders; commercial or organised facilitation carries a minimum one-year sentence. (buzer.de)
The change brings German primary law in line with Directive (EU) 2024/1226 and removes grey areas that had forced border officers to rely on administrative orders rather than statutory authority. For mobility, immigration and travel-risk managers, the message is clear: vet traveller names against the EU consolidated sanctions list before booking tickets that involve German territory—even for airside transits or rail itineraries through Bavaria or Saxony.
VisaHQ’s Germany desk can assist companies and travellers with pre-trip sanctions screening and visa compliance. Through our online portal (https://www.visahq.com/germany/), users can run names against the EU consolidated list, receive real-time entry guidance for Germany, and coordinate any required visas or transit permits—complete with audit-ready documentation that supports corporate due-diligence obligations.
![Germany plugs sanctions loophole: Residence Act now criminalises facilitation of entry for EU-listed individuals]()
Airlines and ground-handlers will have to update DCS (departure-control-system) watch-lists immediately. Failure to block boarding of a sanctioned individual could expose carriers to criminal liability, replacing the previous regime of administrative fines. German business aviation terminals, often used for discreet VIP movements, have been told in a Bundespolizei circular to “exercise elevated diligence” and to file real-time passenger manifests.
Multinationals should update their sanctions-screening workflows for assignees, short-term experts and visiting executives. The criminal provision applies to *any* person facilitating entry, which could include relocation consultants, destination-service providers and even HR staff who arrange airport pick-ups. Internal compliance teams should train staff and document checks to establish a due-diligence defence.
Practically, the amendment may also affect humanitarian corridors: NGOs that move sanctioned individuals for medical or diplomatic reasons will require an explicit federal waiver via the Foreign Office. Mobility advisers should anticipate longer lead times when dealing with travellers from high-risk jurisdictions such as Russia, Iran or North Korea.
The change brings German primary law in line with Directive (EU) 2024/1226 and removes grey areas that had forced border officers to rely on administrative orders rather than statutory authority. For mobility, immigration and travel-risk managers, the message is clear: vet traveller names against the EU consolidated sanctions list before booking tickets that involve German territory—even for airside transits or rail itineraries through Bavaria or Saxony.
VisaHQ’s Germany desk can assist companies and travellers with pre-trip sanctions screening and visa compliance. Through our online portal (https://www.visahq.com/germany/), users can run names against the EU consolidated list, receive real-time entry guidance for Germany, and coordinate any required visas or transit permits—complete with audit-ready documentation that supports corporate due-diligence obligations.
Airlines and ground-handlers will have to update DCS (departure-control-system) watch-lists immediately. Failure to block boarding of a sanctioned individual could expose carriers to criminal liability, replacing the previous regime of administrative fines. German business aviation terminals, often used for discreet VIP movements, have been told in a Bundespolizei circular to “exercise elevated diligence” and to file real-time passenger manifests.
Multinationals should update their sanctions-screening workflows for assignees, short-term experts and visiting executives. The criminal provision applies to *any* person facilitating entry, which could include relocation consultants, destination-service providers and even HR staff who arrange airport pick-ups. Internal compliance teams should train staff and document checks to establish a due-diligence defence.
Practically, the amendment may also affect humanitarian corridors: NGOs that move sanctioned individuals for medical or diplomatic reasons will require an explicit federal waiver via the Foreign Office. Mobility advisers should anticipate longer lead times when dealing with travellers from high-risk jurisdictions such as Russia, Iran or North Korea.
