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Articles by Alexander Ehrle
Germany strengthens EU sanctions enforcement through coordinated authorities
Introduction This chapter surveys EU economic and trade sanctions and their application and enforcement in Germany. In times of increasing geopolitical tension, sanctions are frequently used instruments to persuade states, organisations or individuals to cease conduct contrary to the European Union’s foreign policy objectives. The European Union has more than 40 different sanctions regimes currently in place.
The current state of affairs of FDI screening in Europe
Aside from the revision of the EU FDI Screening Regulation itself, the Commission has found additional instruments needed to respond to geopolitical challenges and their impacts on FDI transactions. Against this background, the Commission has published a proposal for the IAA in order to promote strategic investments in certain industrial sectors.
EU Commission Adopts Delegated Regulation Updating Annex I of the EU Dual-Use Regulation
On 8 September 2025, the EU Commission adopted a Delegated Regulation updating Annex I of the Regulation (EU) 2021/821 (“EU Dual-Use Regulation”). Although the changes have not yet entered into force, they outline the likely amendments to the EU Dual-Use Regulation. Annex I of the EU Dual-Use Regulation lists dual-use items that require export authorization pursuant to Article 3 paragraph 1 EU Dual-Use Regulation.
EU Commission calls on Member states to transpose Directive setting minimum criminalisation standards for sanctions violations
The European Union continues to expand its sanctions regime against Russia and Belarus. The latest – the 18th – EU Russia/Belarus sanctions package was published on 19 July 2025, and included a range of additional sanctions, mainly targeting the Russian energy, banking and military industries, but also individuals and the Russian shadow fleet (see our previous blog post on the 18th sanctions package).
EU Commission calls on Member states to transpose Directive setting minimum criminalisation standards for sanctions violations
The European Union continues to expand its sanctions regime against Russia and Belarus. The latest – the 18th – EU Russia/Belarus sanctions package was published on 19 July 2025, and included a range of additional sanctions, mainly targeting the Russian energy, banking and military industries, but also individuals and the Russian shadow fleet (see our previous blog post on the 18th sanctions package).
Council of the European Union publishes statement on EU export controls on military technology and equipment
The Council has adopted a new decision on arms-related export controls, emphasizing the importance of responsible arms trade policies, cooperation and convergence among Member States, and the prevention of diversion to unauthorized users.
European Union: Commission proposes Simplification Omnibus package and Clean Industrial Deal
In brief Today (26 February 2025), the European Commission published multiple policy documents and legislative proposals, following through on its commitment to improve the EU’s competitiveness under the European Commission's Competitiveness Compass published on 29 January 2025.
European Union: Proposal of amendments to sustainability legislation (Omnibus)
In brief Following on from its commitment to simplify sustainability related obligations under the Competitiveness Compass, the EU Commission has today (26 February 2025) published a proposal for amendments to the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD) and the EU Taxonomy Regulation (EU Taxonomy) (together, the "Omnibus proposal").
EU Establishes New Framework for Restrictive Measures in Response to Russia’s Destabilizing Actions
In a significant move to counter Russia’s destabilizing actions abroad, the Council of the EU has enacted Regulation (EU) 2024/2642 on 8 October 2024 concerning restrictive measures in view of Russia’s hybrid, destabilizing activities (“EU Russia Destabilization Sanctions”). The new sanctions framework aims at targeting individuals and entities involved in hybrid activities that undermine the fundamental values and security of the EU, its member states, and international organizations.
EU Establishes New Framework for Restrictive Measures in Response to Russia’s Destabilizing Actions
In a significant move to counter Russia’s destabilizing actions abroad, the Council of the EU has enacted Regulation (EU) 2024/2642 on 8 October 2024 concerning restrictive measures in view of Russia’s hybrid, destabilizing activities (“EU Russia Destabilization Sanctions”). The new sanctions framework aims at targeting individuals and entities involved in hybrid activities that undermine the fundamental values and security of the EU, its member states, and international organizations.
Supply Chain Due Diligence in the EU - FAQs on the Corporate Sustainability Due Diligence Directive (CSDDD)
On July 25, 2024 the Corporate Sustainability Due Diligence Directive (CSDDD) came into force. Generally, the directive imposes new due diligence obligations on large companies operating in the EU. The legislator requires them to identify, prevent, mitigate, and remediate human rights violations and environmental impacts throughout their entire “chain of actions”. The member states shall transpose the CSDDD into national law by July 26, 2026.
Europe: The EU's Critical Raw Materials Act enters into force
In brief On 23 May 2024, the EU's Critical Raw Materials Act (CRMA), published as Regulation (EU) 2024/1252, entered into force following its adoption by the Council of the EU and European Parliament on 11 April 2024 and its publication in the EU's Official Journal earlier this month. We are pleased to provide you with an assessment of the relevance of the CRMA and the implications it will have for you.
Blog Series: Navigating the Impending Global Sanctions Enforcement Storm - Sanctions Voluntary Self-Disclosure Trends and Potential Pitfalls across the Globe
The sanctions enforcement storm is underway. As we highlighted in the introduction to this blog series, the quickly evolving sanctions landscape of recent years has increased the complexity of compliance. Keeping up with ever-changing multi-jurisdictional sanctions and adapting compliance practices has proven challenging for companies with complex operations and supply chains. Instances of non-compliance can be inevitable.
International: The United Nations adopts its first resolution on AI
In brief On 21 March 2024, the United Nations General Assembly adopted Resolution A/78/L.49 on "Seizing the opportunities of safe, secure and trustworthy artificial intelligence systems for sustainable development". This marks the first-ever resolution adopted by the United Nations (UN) on the matter of artificial intelligence (AI) and is therefore a milestone in its governance.
New Countries Commit to Placing Export Controls Around Spyware Technology: Perspectives on these developments for Poland, Germany, South Korea and Japan
The U.S. has recently made public that a number of countries have joined a pledge to implement export controls on spyware technology. This is part of a broader initiative to establish trade barriers for cyber-related items that could potentially be used in human rights abuses.
Europe: Due Diligence obligations for companies under the new CS3D
In brief In a major shakeup to businesses' obligations relating to human rights, environmental standards, and climate change, the Corporate Sustainability Due Diligence Directive is set to become law. In this article, we focus on the nature of the due diligence obligations: what is actually required in terms of diligence, what types of impacts are covered, etc. Contents What are adverse impacts?
European Union and Germany: Sustainable supply chains - Comparing legal requirements
In brief On 15 March 2024 a new compromise proposal of the Corporate Sustainability Due Diligence Directive (CSDDD) was agreed upon by the EU Member States. The CSDDD sets out human rights and environmental due diligence obligations for companies within and also outside of the EU. Some key regulations have been eased in order to reach an agreement and pave the way for passing the law.
European Union: Member states have reached agreement on Corporate Sustainability Due Diligence Directive
In brief EU member states support narrower scope After long and tough discussions, EU ambassadors adopted a new compromise proposal on the Corporate Sustainability Due Diligence Directive (CSDDD) in Brussels today. Now the measures are likely to pass into law. The next step is for the Parliament to give its approval. Key highlights 1.
Global: Tech Accord to Combat Deceptive Use of AI in 2024 Elections
In brief Leading technology companies have agreed to help prevent deceptive AI content from influencing the many elections worldwide in 2024. This commitment was announced at the Munich Security Conference (MSC). Signatories to the "Tech Accord to Combat Deceptive Use of AI in 2024 Elections" include Adobe, Amazon, Anthropic, Arm, ElevenLabs, Google, IBM, Inflection AI, LinkedIn, McAfee, Meta, Microsoft, Nota, OpenAI, Snap, Stability AI, TikTok, TrendMicro, Truepic, and X.
Europe: The European Union unveils its Artificial Intelligence Office
In brief As part of our commitment to keep you updated on the incipient field of AI-Regulation, we would like to direct your attention to a new development: On 24 January 2024, the EU Commission released its Decision establishing the European Artificial Intelligence Office ("AI Office"). This client alert focuses on the integration timeline, jurisdiction and scope of the AI Office, alongside lingering questions yet to be addressed.
Europe: Legal safeguarding against AI hallucination pitfalls
In brief In a continuation of our commitment to keep you informed of emerging legal challenges, we would like to draw your attention to the issue of AI hallucinations and their implications for the responsible use of AI in your business. This alert aims to provide an overview of the legal ramifications of AI hallucinations, as well as recent regulatory developments in this area.
European Union: The new European Carbon Border Adjustment Mechanism
In brief The European Carbon Border Adjustment Mechanism (CBAM) entered into force on 1 October 2023. The full panoply of obligations will gradually start to apply during the so-called Transitional Phase through 31 December 2025.
International: Review of the UN AI Advisory body interim report on Global AI governance
In brief On 23 December 2023, the United Nations Advisory Body on Artificial Intelligence released an interim report, marking a step forward in the global discourse on Artificial Intelligence (AI) governance. This report, a collaborative effort of experts from government, the private sector, civil society, and academia, calls for a robust global framework to regulate AI. Its publication underscores the urgency and complexity of addressing AI's rapidly evolving landscape.
European Union: Implications of the US Executive Order on Artificial Intelligence for European Businesses
In brief President Biden's issuance of the Executive Order on Artificial Intelligence (AI) on 30 October 2023 marks a significant legislative stride in AI regulation. This directive, extending beyond the US, has profound implications for European businesses and the EU's regulatory landscape on AI.
European Union: The EU has reached a provisional agreement on the Corporate Sustainability Due Diligence Directive
In brief On 14 December 2023, the Council of the EU and the European Parliament have reached a compromise on the Corporate Sustainability Due Diligence Directive (CSDDD), paving the way for its formal adoption by both institutions and thus the CSDDD's entry into force before year end. The CSDDD is intended to significantly reshape corporate due diligence obligations regarding human rights and environmental standards in the EU and beyond.
European Union: AI Act in the EU - What businesses should expect
In brief After a 36-hour negotiation, EU officials have agreed on a provisional deal this weekend on the first comprehensive laws regulating artificial intelligence (AI) use. Key elements of the agreement are: Risk-Based AI Classification: AI systems posing high risk to fundamental rights must meet certain requirements to access EU markets. Systems with limited risk face light transparency obligations, while those with "unacceptable" risk are banned in the EU.
European Union: New AI Regulation Agreement by Germany, France and Italy
In brief We would like to bring to your attention an important development in the field of Artificial Intelligence (AI) regulation in Europe. On 18 November 2023, Germany, France, and Italy reached a significant agreement on the future of AI regulation, marking a step forward in shaping the AI landscape within the European Union (EU). Key Highlights 1.
International: Can a global framework regulate AI Ethics?
In brief The United Kingdom just hosted the first-ever global Artificial Intelligence (AI) Safety Summit on 1 and 2 November 2023, an event that brought international attention to the regulation of Artificial Intelligence (AI). UK Prime Minister Sunak underscored the urgency for global collaboration in the governance of AI, a technology that defies national boundaries and demands a collective regulatory approach.
Germany: Sanctions enforcement - Germany establishes new federal authority also responsible for sanctions enforcement
In brief On 11 October 2023 the German Federal Government approved the Financial Crime Prevention Act (Finanzkriminalitätsbekämpfungsgesetz (FKBG)), which shall come into force on 1 January 2024. The law will establish a new federal authority – the Federal Office to Combat Financial Crime (Bundesamt zur Bekämpfung von Finanzkriminalität (BBF)). This new institution will have competences with respect to the fight of money laundering, sanctions and illicit financial flows.
Global Coalition Renews Enforcement of Russian-Origin Oil Price Cap with Joint Advisory and Other Actions
On 12 October 2023, the Price Cap Coalition (Australia, Canada, the European Union, France, Germany, Italy, Japan, the United Kingdom, and the United States) renewed efforts to ensure effective enforcement of the price cap on Russian-origin oil and petroleum products. Below we summarize the Price Cap Coalition’s joint advisory for the maritime oil industry and other actions taken by the United States.
Global Coalition Renews Enforcement of Russian-Origin Oil Price Cap with Joint Advisory and Other Actions
On 12 October 2023, the Price Cap Coalition (Australia, Canada, the European Union, France, Germany, Italy, Japan, the United Kingdom, and the United States) renewed efforts to ensure effective enforcement of the price cap on Russian-origin oil and petroleum products. Below we summarize the Price Cap Coalition’s joint advisory for the maritime oil industry and other actions taken by the United States.
The EU's Eleventh Sanctions Package against Russia
In brief After intense debates in the Council of the European Union, the EU has agreed on an 11th package of sanctions against Russia and its supporters in their aggression against Ukraine. The relevant Council Regulation (EU) 2023/1214 and Council Regulation (EU) 2023/1215 (respectively amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014) have been published in the Official Journal of the EU, LI 159/1 on 23 June 2023.
The EU’s Eleventh Sanctions Package against Russia
In brief After intense debates in the Council of the European Union, the EU has agreed on an 11th package of sanctions against Russia and its supporters in their aggression against Ukraine. The relevant Council Regulation (EU) 2023/1214 and Council Regulation (EU) 2023/1215 (respectively amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014) have been published in the Official Journal of the EU, LI 159/1 on 23 June 2023.
Blog Series: Sanctions Enforcement Around the G7, the German Perspective
Having focused on the enforcement of sanctions by the United States, United Kingdom and the European Union in the past weeks, this week we will take a closer look at the current enforcement practice of the German authorities and the changes to be expected following the newly announced G7 Enforcement Coordination Mechanism. What are the recent sanctions enforcement trends in Germany?
Blog Series: Sanctions Enforcement Around the G7, the German Perspective
Having focused on the enforcement of sanctions by the United States, United Kingdom and the European Union in the past weeks, this week we will take a closer look at the current enforcement practice of the German authorities and the changes to be expected following the newly announced G7 Enforcement Coordination Mechanism. What are the recent sanctions enforcement trends in Germany?
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