Sanctions 2026

NETHERLANDS Trends and Developments

Trends and Developments Contributed by: Sebastiaan Bennink, Daniel Webb, Carlijn Raijmakers and Matilde Muriotto Bennink Dunin-Wasowicz

Bennink Dunin-Wasowicz is a specialist European law firm with offices in Amsterdam and Paris, focused on economic sanctions, export controls and interna - tional trade compliance. The team combines deep regulatory expertise across EU, Dutch and French frameworks. The firm advises a diverse client base, including multinational corporations in the defence, aerospace, advanced tech and energy sectors, on all aspects of trade law – from preventative compliance strategies to high-stakes enforcement proceedings

and litigation. Recent work includes representing a drone technology company in challenging an export licence denial, advising a semiconductor equipment manufacturer in a complex cross-border licensing dispute, and conducting internal investigations for clients in the aerospace and defence industries. With extensive experience in national security, dual-use regulations and cross-border compliance, the firm is increasingly recognised as a go-to adviser in this niche field.

Authors

Sebastiaan Bennink is a partner and co‑founder of Bennink Dunin- Wasowicz. He is based in Amsterdam and has over a decade of leadership in international trade, sanctions and export control law, specialising in

Carlijn Raijmakers is an associate in Bennink Dunin-Wasowicz’s Amsterdam office, where she works on a broad range of matters involving EU, UK and US sanctions and export control regulations. Her work involves

strategic export controls, complex economic sanctions, compliance programmes, internal investigations and regulatory enforcement. Sebastiaan lectures widely, publishes extensively and is Vice‑Chair of the ABA’s Export Controls & Economic Sanctions Committee. He is admitted to the Amsterdam Bar.

assisting clients in navigating complex regulatory frameworks, including economic sanctions regimes and export control requirements. She supports corporates, organisations and other stakeholders in managing regulatory risks, structuring commercial relationships and developing compliance programmes that are both legally robust and commercially practical. Carlijn also provides guidance on cross-border transactions and ongoing advisory matters for internationally operating businesses, helping clients align their operations with evolving legal and regulatory obligations.

Daniel Webb is an associate in Bennink Dunin-Wasowicz’s Amsterdam office and has a broad range of experience across the trade law landscape. He advises on diverse sanctions and export control matters,

Matilde Muriotto is a legal associate in Bennink Dunin-Wasowicz’s Amsterdam office, where she advises on EU, UK and US sanctions and export controls. She holds an MSc in Political Economy from the University

including asset freezes, import restrictions, export prohibitions, product classifications and transaction screenings. He supports clients with CDIU classification requests and licence applications, including service, divestment, individual and general licences. Daniel has experience in assisting clients in Dutch Customs and FIOD investigations, internal audits and investigations, and responses to KYC requests from Dutch and international banks. He also helps clients develop and formalise internal compliance and product-classification procedures.

of Amsterdam and a BA in International Relations from the University of Groningen; her academic research focused on EU and WTO trade governance, economic statecraft, and the legal and policy dimensions of economic sanctions. Matilde maintains a strong interest in the evolving role of economic statecraft in EU law and practice, bringing an interdisciplinary perspective combining legal, geopolitical and economic analysis.

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