Implementation of sanctions against Russia and Belarus by the Netherlands

Various organisations in the Netherlands are working together to implement and enforce the sanctions against Russia and Belarus. On 21 July 2022 a reporting requirement was introduced for individuals and entities that appear on the sanctions list.

What is the Netherlands doing to implement the sanctions?

To ensure that the sanctions against Russia and Belarus are effective, everyone needs to follow the relevant rules. Financial institutions freeze assets, and companies and consumers stop buying or delivering certain goods. Various government agencies also play a part in implementing the sanctions:

  • The Investment Assessment Office ensures that Dutch businesses cannot exercise rights over companies from Russia or Belarus, or receive any payments from them.
  • Customs oversees the import and export of goods and checks to see whether goods are covered by the sanctions.
  • The Human Environment and Transport Inspectorate oversee sanctions related to aviation and maritime affairs.
  • Together with Customs, the Government Information and Heritage Inspectorate is responsible for controlling the import and export of art and other cultural goods.
  • The Land Registry makes a note on entries for registered goods (such as real estate) that belong to individuals and entities on the sanctions list. That way, anyone consulting the registers can easily see which goods in the registry have been frozen by the sanctions.
  • The Royal Military and Border Police, under the authority of the Minister of Justice and Security, guards the Netherlands’ borders. People who are subject to sanctions are not allowed into the country.
  • De Nederlandsche Bank (the Dutch central bank) and the Dutch Authority for the Financial Markets oversee compliance with the rules governing the operational management of financial institutions, trusts or company service providers, and crypto providers.
  • The Netherlands Food and Consumer Product Safety Authority processes applications for export licences, certifications and import inspections.
  • The Public Prosecution Service investigates and prosecutes individuals and organisations that do not respect the sanctions. They work with the police, other investigative agencies and supervisory bodies.

How does the Netherlands ensure that the sanctions are followed?

To ensure that the sanctions are as effective as possible, all Dutch organisations and market participants must do their part. In addition, individuals and organisations that appear on the sanctions list are required to report any assets they have which are located in the EU. As of 21 July 2022, this must be done within six weeks, or within six weeks of the day their name was added to the sanctions list.

Reporting requirement: parties on the sanctions list must report assets and property

Individuals and entities on the sanctions list are required to report any assets or property they have in EU countries. If they fail to do this, they are in violation of the law. Assets and property in the Netherlands can be reported by email:

Compliance is monitored in a number of ways: 

  • A ‘data team’ has looked into whether any assets that should have been frozen were missed. The team will also search for people associated with sanctioned individuals.
  • A notification requirement will be imposed on non-financial professionals, such as notaries and estate agents. The authorities have been given the power to monitor compliance. To make this possible, the law will have to be amended.
  • A ban has been introduced on providing trust services to individuals and companies – or an ultimate beneficial owner (UBO) – in Russia and Belarus. This will make it more difficult for Russians and Russian companies to do business and divert funds via the Netherlands. A legislative bill to this effect has been submitted.
  • A National Coordinator for Sanctions Compliance and Enforcement has been appointed. The coordinator has examined how the Netherlands could improve the way it implements these sanctions and monitors compliance. His final report sets out the results of this investigation.

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