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Netherlands Antilles: Financial Sanctions and Embargoes

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The Netherlands has a robust sanctions regime in place, implementing both EU and UN sanctions as well as an autonomous sanctions framework. The country’s sanctions regime targets individuals and entities connected to terrorism or violating human rights.

EU Framework for Sanctions

The EU framework provides the foundation for the Netherlands’ sanctions program. EU decisions are converted into Dutch law, which is then enforced through sanctions orders based on the Sanctions Act 1977. The act has extra-territorial reach, applying not only to those within the Netherlands but also to Dutch nationals who breach sanctions while abroad.

UN Sanctions Resolutions

The Netherlands also implements UN sanctions resolutions, converting them into secondary EU law. Additionally, the country has an autonomous sanctions regime, imposing penalties on individuals and entities that are not directly targeted by EU or UN sanctions.

Types of Sanctions in the Netherlands

Sanctions in the Netherlands can include:

  • Arms embargoes
  • Restrictions on specific goods
  • Financial sanctions
  • Asset freezes
  • Travel and visa restrictions
  • And more

The country maintains a list of sanctioned individuals and entities based on national law as well as an up-to-date EU list of organizations and people subject to financial sanctions.

Licensing and Authorization System

A licensing or authorization system is in place for the export, import, and travel of certain goods and services. The Central Import and Export Office is responsible for issuing licenses and authorizations.

Consequences of Breaching EU Sanctions

Breaching EU sanctions can result in:

  • Fines and imprisonment for individuals
  • Fines and penalties for companies, including their directors and officers
  • Statutory maximum fine set out by the Sanctions Act 1977

Regulators Involved in Enforcing Sanctions

Several regulators are involved in enforcing sanctions in the Netherlands, including:

  • Central Import and Export Office
  • Ministry of Foreign Affairs
  • Ministry of Finance
  • De Nederlandsche Bank
  • Netherlands Authority for the Financial Markets
  • Public Prosecution Service
  • Law enforcement agencies
  • Customs Authority
  • FIOD

Important Notice

The information contained on this site is intended as a guide only. While the information it contains is believed to be correct, it is not a substitute for appropriate legal advice. Eversheds Sutherland can take no responsibility for actions taken based on the information contained in this document.

Sanctions Act 1977

The Sanctions Act 1977 sets out the statutory maximum fine for breaches of EU sanctions.