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Subject of the Investigation

The Federal Prosecutor General is examining a possible impairment of Germany’s gas supply through the ownership, control and management structure of the former Gazprom Germania GmbH.

At the end of March 2022, the Berlin-based company was transferred out of the Russian Gazprom group through several share transfers. The Federal Ministry for Economic Affairs and Climate Action identified the Moscow-based JSC Palmary as the indirect acquirer.

The acquisition remained legally ineffective pending completion of the investment review. The resulting restrictions applied in particular to the exercise of voting rights attached to the acquired shares.

Following the transfer, the liquidation of Gazprom Germania GmbH was ordered. The Federal Prosecutor General is examining whether the share transfers and the liquidation decision were intended to impair Germany’s gas supply.

The suspect is accused of supporting the implementation of that liquidation decision.

Critical Function of Gazprom Germania GmbH

In 2022, Gazprom Germania was an energy-sector control and holding node with direct relevance to German supply security.

The company combined storage, trading, procurement, transport and holding functions. According to the Federal Prosecutor General, it held at least 25 percent of Germany’s natural-gas storage capacity.

Its security relevance did not rest solely on physical storage assets. It rested on the company’s ability to integrate storage access, supply contracts, trading operations, payment flows, personnel and operational management processes.

A liquidation would not necessarily have caused an immediate physical failure of storage sites or pipelines. It could, however, have impaired storage management, contract continuity, payment approvals, procurement processes and the allocation of available gas volumes.

The operation occurred during a period of elevated strategic vulnerability. Germany had to build alternative supply chains, secure storage levels for the heating season and stabilise control over energy-sector key entities.

Attack Profile

The suspected conduct concerns a non-kinetic attack vector against critical energy infrastructure.

The case does not centre on an attack against storage facilities, manipulation of pipelines or an intrusion into industrial control systems. The potential access route ran through ownership transfer, corporate voting rights and a liquidation decision.

The potential effect lay in the disruption of management, payment, contractual and control processes. Technical infrastructure can remain available while a company loses its capacity to manage storage, procurement, trading and supply relationships effectively.

The combination of an acquisition that remained legally ineffective pending investment review, an indirect acquirer without an evident sectoral role and an ordered liquidation forms the security-relevant core of the case.

Corporate procedures, registry actions, payment structures and management decisions can, under such conditions, function as an attack channel against critical infrastructure. The operational effect arises through the loss of decision-making authority and effective control.

Legal Assessment

The Federal Prosecutor General is investigating on suspicion of aiding and abetting offences under the Foreign Trade and Payments Act and aiding and abetting attempted anti-constitutional sabotage.

The foreign-trade element concerns the exercise of voting rights contrary to Section 15(4), first sentence, no. 1 of the Foreign Trade and Payments Act. The provision prohibits the exercise of voting rights while a security-relevant acquisition remains legally ineffective pending investment review.

Section 18(1b), no. 1 of the Act criminalises the exercise of voting rights in breach of Section 15(4), first sentence, no. 1. The provision therefore targets the use of voting rights while the acquisition remains subject to investment-control restrictions.

In this case, the alleged exercise of voting rights is relevant because it may have enabled a liquidation decision affecting a company of critical energy-security relevance.

The sabotage allegation concerns Section 88 of the German Criminal Code. The provision covers conduct that wholly or partially disables, or withdraws from its intended purpose, a company or facility serving the public supply of energy or other vital goods, where the conduct is carried out with the intent to promote activities directed against the existence or security of the Federal Republic of Germany.

It is therefore insufficient to establish that the liquidation could have impaired German energy supply. Investigators would additionally have to prove that the conduct was intended to promote activities directed against the existence or security of the Federal Republic of Germany.

Based on the published procedural status, this element remains unresolved and constitutes the central evidentiary threshold of the sabotage allegation.

The investigation therefore combines two levels: the possible unlawful exercise of voting rights and the possible use of that authority to impair an energy-supply structure of security relevance.

The searches serve the preservation of evidence. No indictment, judicial ruling or finding of guilt has been issued. The presumption of innocence applies.

Investigation Led by the Customs Criminal Investigation Office

The Customs Criminal Investigation Office leads the police investigation.

Its role points to evidence streams central to foreign-trade and financial investigations: share transactions, beneficial ownership, registry records, payment flows, contractual chains, communications data and possible circumvention structures.

Its involvement does not reduce the state-security dimension of the case. The sabotage allegation remains part of the proceeding. The Office provides the investigative capability for reconstructing ownership transfers, beneficial ownership, payment flows, corporate records and potential circumvention structures.

For the proof of intent, payment movements, communications, internal documents, ownership structures and decisions concerning the implementation of the liquidation are central. These evidence categories can clarify whether the parties involved understood the company’s supply function and intended, or accepted as a consequence, an impairment of German gas supply.

State Countermeasure

In April 2022, the German government appointed the Federal Network Agency as trustee for Gazprom Germania and thereby removed operational control from the then owners.

The measure prevented the liquidation and secured storage management, contract execution, payment capacity and supply relationships. The subsequent transfer of the SEFE group into federal ownership stabilised German control over the affected trading, storage and procurement structures.

Key Investigative Questions

The evidence review must establish who initiated, coordinated and financed the ownership transfer, liquidation order and planned implementation measures.

A central issue is what knowledge the parties involved had regarding Gazprom Germania’s role in German gas supply. For the sabotage allegation, it is decisive whether impairment of German gas supply was intended or accepted as a consequence of the conduct.

Further examination will focus on communications links, payment flows, contractual records, beneficial ownership, chains of instruction and internal decision-making processes within the companies involved.

The published statement contains no substantiated information on direct instructions from Russian government bodies, Russian intelligence services or the leadership of the Gazprom group. A state or intelligence-service attribution is not sustainable on the basis of the known procedural status.

Media reports concerning individuals in the environment of JSC Palmary remain an unconfirmed and secondary-source finding and are not assessed here.

Security Assessment

The case concerns an operational vulnerability in the protection of critical infrastructure.

Energy supply depends on storage facilities, pipeline networks and digital control systems. It also depends on ownership rights, corporate management, payment capacity, contractual control, personnel structures and legal authority to act.

An actor can impair supply security without attacking physical infrastructure. The loss of management and control capacity can destabilise storage management, procurement, trading and supply chains within a short period.

German security authorities therefore require scrutiny of acquisitions pending investment review, acquirers without a plausible sectoral role, liquidation decisions, atypical financing, concealed control chains, unusual contract transfers and interference with operational management functions.

The protection of critical energy infrastructure requires a combined situational picture integrating investment screening, financial investigation, registry analysis, economic intelligence, intelligence reporting and resilience planning.

Situation Assessment

The Federal Prosecutor General does not treat the case solely as a foreign-trade violation.

The sabotage allegation places the possible liquidation of Gazprom Germania GmbH within the spectrum of hybrid threats against critical energy infrastructure. The suspected attack route ran through ownership and liquidation mechanisms. Its potential effect would have been to impair German operational capacity in the gas sector during an acute supply crisis.

The criminal-law sustainability of the case depends on three elements: proof of concrete assistance, proof of intent to impair German gas supply and proof that the conduct was intended to promote activities directed against the existence or security of the Federal Republic of Germany.

Critical energy infrastructure can be pressured through corporate structures, financing, ownership control and management decisions as effectively as through physical or digital sabotage.

References

Federal Prosecutor General at the Federal Court of Justice
Searches on suspicion of Foreign Trade and Payments Act violations and attempted anti-constitutional sabotage in connection with the liquidation of Gazprom Germania GmbH, 24 June 2026.
www⁠.generalbundesanwalt.de/SharedDocs/Pressemitteilungen/DE/2026/Pressemitteilung-vom-24-06-2026.html

Federal Ministry for Economic Affairs and Climate Action
Appointment of the Federal Network Agency as trustee for Gazprom Germania; acquisition by JSC Palmary legally ineffective pending investment review, 4 April 2022.
www⁠.bundeswirtschaftsministerium.de/Redaktion/DE/Pressemitteilungen/2022/04/20220404-bmwk-setzt-bundesnetzagentur-als-treuhanderin-fur-gazprom-germania-ein-erwerb-der-gazprom-germania-gmbh-durch-jsc-palmary-schwebend-unwirksam.html

Federal Ministry of Justice / Federal Office of Justice
Foreign Trade and Payments Act, Section 15(4), first sentence, no. 1 and Section 18(1b), no. 1.
www⁠.gesetze-im-internet.de/awg_2013/__15.html
www⁠.gesetze-im-internet.de/awg_2013/__18.html

Federal Ministry of Justice / Federal Office of Justice
German Criminal Code, Section 88: Anti-Constitutional Sabotage.
www⁠.gesetze-im-internet.de/stgb/__88.html