Your analogy doesn’t work, since that is a crime that involves a us citizen. Moreover us claims jurisdiction of anyone all over the world uses usd.
With the heil we have a “victimless” crime that takes place in the other country and doesn’t involve anyone who is German (or uses German currency).
This is comparable to Poland wanting to prosecute people who go to have abortions abroad. Or Texas trying to prosecute people going for abortions to other states. This is just not how jurisdiction works.
the main takeaway about things working between federal nation states is that they work like they work because there is no-one above federal nation states to tell them how jurisdiction works in such cases.
If powerful enough nation says that they have jurisdiction and no-one opposes them then they have it.
I fear that Germany might not want to anger the us.