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Dutch Financial Sanctions Compliance: What You Need to Know

The Netherlands has a comprehensive sanctions regime in place, relying on both EU and UN sanctions as well as its own autonomous measures. The country’s sanctions framework is designed to target individuals and entities connected to terrorism, proliferation of weapons of mass destruction, and human rights violations.

EU Sanctions

The Netherlands implements EU sanctions through the conversion of EU decisions into Dutch law. These sanctions typically target countries, individuals, and entities that are deemed a threat to the country or the international community. The sanctions can include:

  • Arms embargoes
  • Trade restrictions
  • Asset freezes
  • Travel bans
  • Financial sanctions

UN Sanctions

The Netherlands also implements UN sanctions, which are converted into secondary EU law. These sanctions are typically aimed at countries or entities that are listed on the UN’s Consolidated List of persons, groups, and entities subject to sanctions.

Autonomous Sanctions

In addition to implementing EU and UN sanctions, the Netherlands has its own autonomous sanctions regime. This allows the country to target specific individuals and entities that pose a threat to national security or international stability.

Sanctions Regime in the Netherlands

The Dutch sanctions regime includes various types of sanctions, including:

  • Arms embargoes
  • Embargoes on specific goods
  • Financial sanctions restricting loans and credit
  • Asset freezes targeting specific individuals and companies
  • Travel and visa restrictions for certain individuals

List of Sanctioned Individuals and Entities

The Netherlands maintains a list of sanctioned individuals and entities based on national law. The country also uses the EU’s updated list of organizations and people subject to financial sanctions.

Licensing and Authorization System

The Central Import and Export Office (CDIU) is responsible for issuing licenses for the import and export of certain goods and services. This includes strategic goods and services that are subject to specific regulations.

Consequences of Breaching Sanctions

Breaching EU sanctions can result in fines, imprisonment, or both. For companies, the entity itself will be fined, along with directors and/or officers who are involved in the breach.

Regulators in the Netherlands

The following regulators are responsible for enforcing financial sanctions in the Netherlands:

  • The Central Import and Export Office (CDIU)
  • The Ministry of Foreign Affairs
  • The Ministry of Finance
  • De Nederlandsche Bank (DNB)
  • The Netherlands Authority for the Financial Markets (AFM)
  • The Public Prosecution Service
  • The General Intelligence and Security Service (AIVD)

Conclusion

For further guidance on financial sanctions compliance in the Netherlands, please consult with a qualified legal professional.