Sanctions 2026

NETHERLANDS Law and Practice Contributed by: Sebastiaan Bennink, Daniel Webb, Charlotte Loomans and Siqi Zhao, Bennink Dunin-Wasowicz

3. Recent and Future Legal Developments 3.1 Significant Court Decisions or Legal Developments Dutch authorities have intensified efforts to enforce sanctions, with a particular focus on prosecuting vio - lations and addressing circumvention schemes. In September 2017, the Dutch Public Prosecution Ser - vice initiated a criminal investigation into the involve - ment of several Dutch companies, including Dieseko, in the construction of the Crimean Bridge in Russia. The investigation found that Dieseko had breached sanctions by selling prohibited goods and providing technical assistance in relation to the supplied prod - ucts. In July 2024, the case was concluded by way of a settlement agreement, which included both a finan - cial penalty and a confiscation component. In 2024, Dutch courts delivered judgments in two cases resulting in the conviction of natural persons. • On 17 October 2024, the District Court of Rotter - dam convicted a Russian national residing in the Netherlands and imposed a custodial sentence of 450 days, 344 days of which were conditional, minus time spent in pre-trial detention. The sen - tence also included a probation period of two years and a community service order of 240 hours, or alternatively 120 days’ imprisonment. The convic - tion related to the supply and export to Russian companies in Russia – via transit countries – of electronic dual-use goods and technology, certain luxury items, and goods capable of contributing to the enhancement of Russia’s industrial capacity. • On 22 November 2024, the District Court of Rotter - dam sentenced a natural person to imprisonment of 300 days, 195 days of which were conditional, minus pre-trial detention with a probation period of two years, and a community service order of 240 hours, or alternatively 120 days’ imprisonment. This individual, together with his accomplices, sup - plied aviation components to a company in Rus - sia through circumvention routes through Turkey, Serbia, the United Arab Emirates and Kyrgyzstan.

3.2 Future Developments The Dutch government is undertaking a 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.

4. Delisting Challenges 4.1 Process

In relation to EU sanctions, designations of persons and entities are made by the European Council. Con - sequently, listings must be challenged at the EU level, which can be done by two means: • before the Council, by requesting its delisting via e-mail or letter; or • before the General Court of the EU, by challenging the Council’s decision pursuant to Articles 263 and 275 of the TFEU; this judgment may be appealed to the Court of Justice of the EU (CJEU). 4.2 Remedies Delisting challenges related to EU sanctions may result in: • the removal of the designated person from the list (from the date of the original listing or as of the relisting date); and/or • damages for the loss caused by the unlawful list - ing. 4.3 Timing Where a request for delisting is taken to court, it usu - ally takes from one to two years for the court to reach a decision. 5. Trade and Export Restrictions 5.1 Services Certain EU sanctions regimes contain multiple import and export bans on the following services to or from other countries:

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