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Iran embargo - criminal proceedings despite loosenings


Much of the Iran embargo has been lifted. Nevertheless, the public prosecutor’s office is pursuing old infringements, so that criminal law consequences can still be expected. Legal proceedings are currently pending against three German nationals who delivered special valves to Iran between 2010 and 2011 as employees of two companies. The order volume amounted to approx. 1 million euros.

In the opinion of the public prosecutor’s office, the accused faked false end users of their deliveries. In fact, the valves were intended for an Iranian company that was entrusted with the construction of the heavy water reactor in Arak. However, this was listed in the annexes to the Iran embargo regulation. This prohibited deliveries of any kind to this company. The accused are threatened with punishment according to § 18 para. 1, 7 AWG, which would not result in a prison sentence of less than one year.

Most Iran sanctions have now been lifted. However, there are still prohibitions and approval obligations with regard to individual goods, in particular dual-use goods.

The current proceedings show that despite the relaxation of Iran sanctions, all violations – including those from the past – are still being severely punished. If you have any questions regarding current Iran sanctions or foreign trade law, please do not hesitate to contact us


Attorney Dr. Tristan Wegner

Ihr Ansprechpartner

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