Control over a company or asset depends on who actually holds it — and whether that person is subject to restrictions that affect the validity of any transaction. A sanctions or PEP designation does not merely create compliance risk. It determines whether a counterparty can legally act, whether funds can move, and whether a shareholder's exercise of rights is enforceable. This extract addresses that layer directly: it establishes the status of a named person or entity against the lists that govern those questions in Germany and at EU level.
Germany operates within the EU sanctions framework. The primary instrument is the EU Financial Sanctions Files, maintained by the European Commission's Office of Financial Sanctions Implementation equivalent — the EU Consolidated List. German national measures are administered by BAFA and the Deutsche Bundesbank for financial sanctions. Both layers must be checked. A result from one without the other is incomplete.
What a sanctions and PEP extract establishes
The extract produces a documented result for each of the following checks:
- EU Consolidated Sanctions List (asset freezes, travel bans, arms embargoes by designated person or entity name)
- German national restrictive measures administered by BAFA
- UN Security Council consolidated list, as incorporated into EU law
- PEP status derived from official German parliamentary and governmental records
- Adverse media and PEP aggregator cross-reference, where the Standard and Extended tiers apply
Each check returns one of three outcomes: no match found, potential match requiring review, or confirmed match with list reference. The extract states which outcome applies and identifies the source and retrieval date for each list searched.
The extract does not produce a legal opinion on what a match means for a specific transaction. That is a separate instruction. The extract establishes the factual record.
Why Germany requires a multi-layer search
Germany does not maintain a single national sanctions register that consolidates all applicable restrictions. The EU Consolidated List is the operative instrument for most asset-freeze and travel-ban designations. BAFA administers export control and certain sector-specific restrictions. The Deutsche Bundesbank issues guidance on financial sanctions implementation. These are separate sources with separate update cycles.
A search of only one source produces a result that is accurate for that source and incomplete for the question. The extract covers all three layers as a minimum at Signal tier.
PEP status adds a further layer. Germany has no official PEP register. PEP classification is derived from position: members of the Bundestag, Bundesrat, federal ministers, state-level equivalents, senior judicial appointments, and their immediate family members and known close associates. The sources for this derivation are official gazette records, parliamentary registers, and aggregated commercial databases that compile and update these records. The extract identifies which sources were searched and on what date.
| Layer | Source | Update frequency |
|---|---|---|
| EU Consolidated Sanctions List | European Commission EFSF | Daily |
| German national measures | BAFA | As issued |
| UN SC list (EU-incorporated) | EU Consolidated List | Daily |
| PEP — parliamentary | Bundestag / Bundesrat registers | Per session |
| PEP — executive | Federal Gazette (Bundesanzeiger) | As published |
| Adverse media / PEP aggregator | Third-party database | Varies by provider |
The procedure for ordering this extract
A request is submitted through the contact form. The following information is required at the time of submission:
- Full legal name of the individual or entity to be searched
- Date of birth (for individuals) or registration number (for legal entities)
- Nationality or jurisdiction of incorporation
- Any known aliases or former names
- The purpose of the search (transaction due diligence, onboarding, periodic review)
The purpose declaration is required for access to certain third-party PEP databases. It is not a formality. Some aggregated databases require a stated legitimate interest before returning results. The extract documents whether this condition was met and what it permitted.
Timeline from confirmed instruction to delivery of the extract: Signal tier, two business days. Standard tier, three business days. Extended tier, five business days.
What is included at each tier
| Tier | Price | What is included | Not included |
|---|---|---|---|
| Signal | €440 | EU Consolidated List, BAFA national measures, UN SC list (EU-incorporated), written match/no-match result per list, source identification, retrieval date | PEP check, adverse media, family and associate screening, aggregator cross-reference |
| Standard | €890 | Everything in Signal, plus PEP check from official German parliamentary and governmental records, one commercial PEP aggregator, written result with source and date per check | Adverse media screening, extended family and associate network, second aggregator cross-reference |
| Extended | €1800 | Everything in Standard, plus adverse media review, extended family and close associate screening, second PEP aggregator cross-reference, consolidated summary with discrepancy notation | Ongoing monitoring, legal qualification of results, representation |
The limit of what the sources allow
The EU Consolidated List is updated daily. A search result is accurate as of the retrieval date stated in the extract. A designation issued after that date is not reflected. The extract states its retrieval date precisely for this reason.
BAFA national measures are published as they are issued. There is no guaranteed publication lag, but the extract is drawn on the date of retrieval, not on a cached or aggregated copy.
PEP status is not a binary or permanent condition. A person who held a qualifying position and has since left it may remain on commercial PEP lists for a period determined by the database provider's policy. The extract identifies whether a result derives from a current position or a historical one, and from which source.
Germany has no official PEP register. This is not a gap in the extract — it is a structural feature of the German system. The extract covers the sources that exist. It states explicitly what no source covers: informal influence, undisclosed family relationships, and positions in non-German jurisdictions that are not captured by the databases searched.
A negative result — no match found across all lists searched — does not certify the absence of any restriction. It certifies that no match was found in the sources searched on the date stated. The distinction matters. The extract is worded accordingly.
Where the sources disagree
Commercial PEP aggregators do not always agree on whether a named individual qualifies as a PEP or as a close associate. Discrepancies arise from different interpretations of "close associate," different update cycles, and different coverage of regional and municipal positions. Where the Standard or Extended tier returns a discrepancy between sources, the extract notes it explicitly. The discrepancy itself is a result. It is not resolved by selecting one source over another.
Where the EU Consolidated List and a commercial aggregator return different results for the same name, the extract reports both results with their respective sources and dates. The EU Consolidated List is the operative legal instrument. The aggregator result is reported as additional context.
FAQ
Does a negative result mean the person is not a PEP? A negative result means no match was found in the sources searched on the date stated. Germany has no official PEP register. The result reflects the coverage of the databases searched. If a person holds a qualifying position that is not captured by those databases, the result will not reflect it. The extract states the sources searched and their coverage scope.
Is the EU Consolidated List the only sanctions list that applies in Germany? No. German national measures administered by BAFA apply in addition to the EU Consolidated List. UN Security Council measures are incorporated into the EU list and are covered by that search. Sector-specific restrictions — export controls, arms embargoes — may require separate checks not covered by this extract. The extract covers the layers stated in the tier description.
How current is the result? Each list is searched on the date of retrieval, which is stated in the extract. The EU Consolidated List is updated daily. BAFA measures are published as issued. The extract is not a subscription product and does not update automatically after delivery.
What happens if a potential match is returned? A potential match is a name similarity that requires review. The extract documents the potential match, the source, and the basis for the similarity. It does not resolve the match into a confirmed designation or a confirmed non-match. Resolution requires additional steps — identity verification, further document review — which are outside the scope of this extract and are available on instruction.
Can the extract cover entities as well as individuals? Yes. Legal entities are searched against the EU Consolidated List, BAFA measures, and the UN SC list. PEP checks apply to individuals. For an entity, the Standard and Extended tiers include a check of the named directors and beneficial owners against PEP databases, where those names are provided at the time of instruction.
Sources:
- EU Financial Sanctions Files (EFSF) — European Commission — https://eeas.europa.eu/topics/sanctions-policy/8442/consolidated-list-of-sanctions_en — extracted 2026-09-15
- Bundesamt für Wirtschaft und Ausfuhrkontrolle (BAFA) — https://www.bafa.de — extracted 2026-09-15
- Bundestag member register — https://www.bundestag.de/abgeordnete — extracted 2026-09-10
- Bundesanzeiger (Federal Gazette) — https://www.bundesanzeiger.de — extracted 2026-09-10
- UN Security Council Consolidated List (as incorporated into EU law) — https://www.un.org/securitycouncil/content/un-sc-consolidated-list — extracted 2026-09-15
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Disclaimer: This report is a factual compilation from official registers and public sources. It is provided for informational purposes only, does not constitute legal advice, and contains no legal qualification of the facts established. VLO Law Firm assumes no liability for actions taken or not taken based on this material. For advice regarding your particular situation, please contact info@vlolawfirm.com.
Author: Katharina Berg — Partner, Central Europe, VLO Law Firm
