NETHERLANDS Law and Practice Contributed by: Sebastiaan Bennink, Daniel Webb, Charlotte Loomans and Siqi Zhao, Bennink Dunin-Wasowicz
Bennink Dunin-Wasowicz Joan Muyskenweg 22 1096 CJ Amsterdam The Netherlands Tel: +31 20 764 07 63 Email: amsterdam@benninkdunin.com Web: www.benninkdunin.com
1. Trends and Overview 1.1 Sanctions Market
extended the transaction ban and introduced the pos - sibility of a full third-country ban on crypto-asset ser - vices for the first time, alongside a ban on 14 crypto platforms based in Georgia, Panama, the UAE, the Marshall Islands, Kyrgyzstan and Belarus. On energy, it paused the automatic oil price cap adjustment until 15 July 2027, expanded shadow-fleet and refinery- related restrictions, and introduced a notification obli - gation for LNG tanker sales to Russia, while also tight - ening dual-use export controls and mirroring several trade and legal protection measures against Belarus. At the national level, the sanctions landscape in the Netherlands has continued to evolve. EU operators face increasingly complex and far-reaching restric - tions stemming from the EU framework, and the Neth - erlands has significantly intensified its enforcement of international sanctions. In 2025 and 2026, the Dutch Public Prosecution Service launched multiple inves - tigations into sanctions violations and circumvention efforts, demonstrating that compliance failures at any scale carry real prosecutorial risk. The Dutch government is undertaking legislative reform of the Sanctions Act 1977, aiming to replace it with a new International Sanctions Act. This legisla - tion will broaden the scope for administrative enforce - ment, complementing existing criminal measures and enhancing the overall sanctions framework. The latest version of the bill was published on 17 June 2026. 1.2 Key Trends The field of sanctions in the Netherlands has been significantly influenced by developments in the EU sanctions regimes. Key trends include:
Over the past 12 months, the European Union (EU) has adopted its 18th, 19th, 20th and 21st sanctions packages against Russia, significantly expanding the scope of restrictive measures. This sanctions regime now encompasses not only traditional asset freezes, trade and financial restrictions, arms embargoes and travel bans, but also far-reaching sectoral and tech - nology export controls, prohibitions on the provision of crypto-asset and fintech services, comprehensive transaction bans targeting key Russian entities, and new restrictions relating to the protection of intellec - tual property rights of EU companies in Russia. The 18th package lowered the oil price cap and intro - duced a catch-all mechanism to curb circumvention via third countries, while the 19th introduced a Rus - sian LNG import ban and tightened restrictions on Rosneft and Gazprom Neft. The 20th package, adopted after a near six-month deadlock caused by Hungary’s veto, marked a struc - tural shift toward targeting evasion networks rather than isolated listings, activating the Anti-Circumven - tion tool against Kyrgyzstan for the first time and intro - ducing a sectoral ban on Russian crypto-asset provid - ers. Throughout, the EU has intensified shadow-fleet listings, port-level transaction bans and oil price cap enforcement, while expanding protections for EU operators against Russian judicial countermeasures. The 21st package, adopted in July 2026, delivered the largest batch of individual listings in four years. It
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