NETHERLANDS Law and Practice Contributed by: Sebastiaan Bennink, Daniel Webb, Charlotte Loomans and Siqi Zhao, Bennink Dunin-Wasowicz
1.4.3 Domestic and/or Supranational Measures The Dutch government does not generally impose sanctions unilaterally. Instead, it implements sanctions adopted by the United Nations or the European Union, based on the view that sanctions are most effective when imposed collectively by a coalition of countries. Sanctions imposed in the Netherlands are comprised of over 40 different EU regimes, some implementing UN Security Council resolutions, but also a National Terrorism List adopted in accordance with UN Securi - ty Council Resolution 1373 (2001), which can be con - sidered as a unilateral sanctions list. Furthermore, in July 2026, the Dutch government approved the Tem - porary Sanctions Decree on Unlawful Settlements in the Israeli-Occupied Territories in implementation of the ICJ’s July 2024 advisory opinion and relevant UN resolutions. In the Netherlands, the leading National Competent Authority (NCA) for sanctions policy is the Ministry of Foreign Affairs, which is responsible for: • the interpretation of EU restrictive measures; • the co-ordination of national implementation; and • the representation of the Netherlands in EU and international sanctions fora. It also provides guidance to other competent authori - ties and stakeholders regarding the scope and appli - cation of sanctions. 2. Overview of Regulatory Field 2.1 Primary Regulators Other competent authorities are entrusted with man - dates tailored to their sectoral expertise. These may include: • the Ministry of Finance, which is responsible for provisions relating to the financial sector and finan - cial transactions; • the Ministry of Infrastructure and Water Manage - ment, which oversees provisions concerning transport infrastructure, including roads, railways, waterways and airways, with a particular focus on Dutch ports;
• the Ministry of Economic Affairs, which focuses on issues relating to economic competitiveness and trade; • the Ministry of Education, Culture and Science, which is responsible for education, cultural devel - opment, cultural heritage and scientific research; • the Ministry of Climate Policy and Green Growth, which handles matters related to the energy sector; • the Ministry of Agriculture, Fisheries, Food Secu - rity and Nature, which oversees sustainable food production, environmental protection and rural development; • the Ministry of Housing and Spatial Planning, which is responsible for housing policy and the release or provision of economic resources connected to real estate; • the Ministry of Justice and Security, which ensures the enforcement of legal measures and upholds the rule of law in the context of sanctions; • the National and International Road Transport Organisation (NIWO), which is responsible for the licensing of road transport operators; and • the Human Environment and Transport Inspector - ate (ILT), which oversees access for ships entering Dutch waters and aircraft seeking entry into Dutch airspace. 2.2 Enforcement 2.2.1 Enforcement Responsibilities Although there is more co-ordination and communica - tion amongst various NCAs, the enforcement of sanc - tions in the Netherlands is not yet centralised. Differ - ent NCAs are responsible for enforcement within their respective areas of competence, as follows: • the Central Import and Export Service ( Centrale Dienst In - en Uitvoer , or CDIU) supervises the import and export of goods and is in charge of issuing licences; • the Tax and Customs Administration ( Belasting- dienst / Douane Noord ), through the Precursors, Origin, Strategic Goods and Sanctions Legislation team (POSS), supervises compliance with sanc - tions; • the Dutch Central Bank ( De Nederlandsche Bank , or DNB) and the Dutch Financial Markets Author - ity ( Autoriteit Financiële Markten , or AFM) oversee
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