Dutch Authorities Unite to Enforce Financial Sanctions Against Russia and Belarus

Introduction

As part of the global efforts to impose financial sanctions on Russia and Belarus, the Dutch government has introduced a new reporting requirement for individuals and entities listed on sanctions lists. This move aims to ensure that financial sanctions are implemented effectively and efficiently.

Collaborative Efforts by Dutch Government Agencies

A range of government agencies and organizations in the Netherlands have joined forces to oversee compliance with the sanctions. These include:

• Investment Assessment Office: Prevents Dutch businesses from exercising rights over Russian or Belarusian companies or receiving payments from them.
• Customs: Monitors the import and export of goods and checks whether they are covered by the sanctions.
• Human Environment and Transport Inspectorate: Oversees sanctions related to aviation and maritime affairs.
• Government Information and Heritage Inspectorate: Controls the import and export of art and cultural goods, in collaboration with Customs.
• Land Registry: Keeps a record of registered goods owned by individuals or entities on the sanctions list, allowing for easy identification of frozen assets.
• Royal Military and Border Police: Guards the country’s borders and prevents those subject to sanctions from entering under the authority of the Minister of Justice and Security.
• De Nederlandsche Bank and the Dutch Authority for the Financial Markets: Oversee compliance with financial regulations governing institutions, trusts, company service providers, and crypto providers.
• Netherlands Food and Consumer Product Safety Authority: Processes applications for export licenses, certifications, and import inspections.
• Public Prosecution Service: Investigates and prosecutes individuals and organizations that fail to comply with the sanctions, working closely with police, investigative agencies, and supervisory bodies.

Compliance Requirements

To ensure effective implementation of the sanctions, all Dutch organizations and market participants must take steps to comply. Additionally, individuals and entities listed on the sanctions list are required to report any assets located within the EU within six weeks of being added to the list.

European Union Reporting Requirements

The European Union has also introduced reporting requirements for member states, including the Netherlands. Market participants must provide information about frozen reserves and assets of the Central Bank of Russia in the country, as well as information on frozen funds and economic resources. This data will help provide a clear picture of sanctions compliance at the European level.

Additional Resources

For more information and guidance on filling out the required forms, market participants can refer to the European Commission’s FAQs and submit their reports to the relevant authorities.