On 12 May 2011, a Munich court convicted John Demjanjuk, a former guard at the Sobibor extermination camp, of aiding and abetting the murder of 28,060 people. No single killing could be attributed to him personally. The court held that he had been part of the machinery of extermination. The verdict never became final because he died before the appeals were decided. On 15 July 2015, Oskar Gröning, called the bookkeeper of Auschwitz by the press, was sentenced to four years. The Federal Court of Justice upheld the verdict in 2016.

For Auschwitz, prosecutors had long needed proof of direct involvement in a killing. An investigation against Gröning in 1985 was dropped.