Overview
Austria is a UN and EU member state and implements UN and EU sanctions. Austria also has its own autonomous sanctions.
The Sanctions Act 2024, and the Foreign Trade Act 2011 govern the implementation in Austria of EU, UN, and Austrian sanctions. Section 2 of the Sanctions Act 2024 governs EU and UN sanctions, section 4 governs the implementation of national sanctions.
EU and UN Sanctions
The Federal Minister of Finance (in agreement with the Federal Minister for European and International Affairs and the Federal Minister of the Interior) can order asset freezing restrictions on and the prohibition of direct or indirect provision of assets to (a) people who commit/attempt to commit/participate/facilitate terrorist acts and persons/entities subject to UN or EU sanctions; (b) entities directly or indirectly owned or controlled by them; and (c) people or entities acting on their behalf.
The Federal Minister of Finance (in agreement with the Federal Minister for European and International Affairs and the Federal Minister of the Interior) can, under s2 of the Sanctions Act 2024, order the following to the extent necessary to implement internationally binding sanctions:
- Seizing and confiscation of transport and goods
- Prohibition of provision of services
- Exemption from the obligation to fulfil civil law claims if connected with contracts affected by UN or EU sanctions
- Exemption from prohibition of providing funds where the funds are to provide humanitarian assistance
Autonomous Sanctions
The Federal Minister of Finance (in agreement with the Federal Minister for European and International Affairs and the Federal Minister of the Interior) can, under s4 of the Sanctions Act 2024, impose Austrian sanctions against people or entities if either:
- There is a risk that planned sanction measures, which would be made binding under international law by the UN or the EU, will be frustrated; or
- Sanctions are necessary in the context of international cooperation to prevent: terrorism, weapons proliferation, trafficking in dual-use goods or technologies, or corruption
and it is necessary to safeguard Austria’s foreign and security policy, is in line with EU law, and does not conflict with Austria’s international obligations.
No designations have been made under Austria’s autonomous sanctions regime provided for by the 2024 Act.
Financial Sanctions
The Austrian National Bank (Österreichische Nationalbank (OeNB)) is responsible for monitoring compliance with sanctions & granting licences.
In December 2024, Austria’s Parliament passed legislation that will transfer responsibility for financial sanctions to the Financial Market Authority in 2026. The FMA will take over all the OeNB’s duties with regards to financial sanctions in 2026; press release. The FMA is responsible for the prevention of money laundering and terrorist financing.
Trade Sanctions
The Export Control Department of the Federal Ministry of Labour and Economy (BMAW) is responsible for goods-related sanctions (including export bans, embargoes, goods restrictions – e.g. dual-use goods or chemical weapons). Austria’s customs administration assists with enforcement. Enforcement of trade sanctions consists of administrative penalties imposed by the BMAW and criminal penalties (prosecuted by the public prosecutor‘s office and imposed by the courts).
National Competent Authorities
Federal Ministry of the Interior
Federal Ministry of Labour and Economics (BMAW)
Federal Ministry for Climate Action, Environment, Energy, Mobility, Innovation and Technology
Austrian National Bank (Österreichische Nationalbank OeNB) regulates financial sanctions
Directorate of State Protection and Intelligence (Direktion Staatsschutz und Nachrichtendienst (DSN)) for reporting
Legislation
Sanctions Lists
EU sanctions are directly applicable in Austria – EU Sanctions Lists.
Austria also implements UN sanctions, see UN Sanctions Lists.
The OeNB in 2009 published a list of people and entities subject to sanctions (based on UN designations), which remains in force. No new listings have been enacted based on the Sanctions Act 2024.
Austria does not maintain a public list of autonomous sanctions.
Guidance
Trade Policy Measures and Foreign Trade Law
OeNB Guidance
Will there be a change in the flow of goods trade due to export sanctions against Russia?
OeNB Guide to Russia/Belarus Sanctions
Information brief of the OeNB about sanctions to counter the financing of terrorism
Enforcement
The Austrian National Bank (OeNB) is responsible for monitoring compliance, granting exemptions, and issuing financial sanctions against certain individuals. Responsibility will transfer to the FMA in 2026.
Sanctions breaches are punishable as criminal offences or administrative offences (under §§16-18 of the Sanctions Act 2024 and section 2 of the Foreign Trade Act 2011) depending on the value of the offence.
Breaches of financial sanctions and prohibitions on providing services are criminal acts punishable by imprisonment from 6 months to 5 years if the value of the funds, economic resources or services exceeds EUR 100k.
Breaches below this value threshold and infringements of licensing and reporting obligations are punishable with administrative penal provisions, which include fines of up to €150,000 by the district administrative authority. Serious or repeated infringements of reporting obligations may be subject to fines of up to €5 million (or double the economic benefit resulting from the infringement; for companies, the maximum fine will increase to up to 10% of consolidated turnover as of 1 January 2026).
The Export Control Department of the Federal Ministry of Labour and Economy (BMAW) is responsible for goods-related sanctions.
Violations of goods-related sanctions are criminal acts punishable by imprisonment of up to 3 years, or 6 months up to five years if the violation is committed with the intention of obtaining a continuous income. Negligent violations of goods embargos are punishable by imprisonment of up to one year, or a monetary fine. Companies may be liable for violations under the Association Responsibility Act, which provides for fines of up to EUR 3 million.
Reporting
Reporting obligations guidance
Funds
Under s12(8) of the Sanctions Act 2024, financial market participants must report to the OeNB:
- Frozen accounts held in Austria by any people or entities sanctioned by the EU/UN or Austria, reported on a quarterly basis (form);
- Information relating to funds held in the EU by an EU-sanctioned person (form)
- Deposits of more than €100k from Russian nationals, organisation, or bodies (or entities 50% owned by a Russian national, organisation or body). This information should be submitted every 12 months (form);
- ‘returned’ transactions, meaning payments ordered by a non-sanctioned person to a sanctioned person that was stopped by a credit institution (form).
By Article 9 of Regulation (EU) 269/2014, sanctioned persons must report to the OeNB all assets attributable to them that are held by Austrian credit, financial and payment institutions (form).
Economic Resources
Economic resources (located in Austria) of sanctioned individuals and entities must be reported to the Directorate of State Protection and Intelligence (Direktion Staatsschutz und Nachrichtendienst (DSN)), by articles 8 and 9 of Regulation (EU) 269/2014. Economic resources are assets of every kind, whether tangible or intangible, movable or immovable, which are not funds but may be used to obtain funds, goods, or services.
Reporting parties should use this form.
Export controls
The Federal Ministry of Labour and Economy (BMAW) is responsible for export controls. BMAW processes applications for licences for the export of firearms, defence goods and dual-use goods, goods subject to trade embargos and goods that fall under the EU-Anti-Torture Regulation.
If the goods are classified as war material by the Austrian War Material Act (e.g. tanks and fully automatic weapons), the Federal Ministry of Interior is responsible for licensing.