Sanctions 2026

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

at modernising the Sanctiewet , which ultimately resulted in a proposal to replace it with a new Inter - national Sanctions Act ( Wet internationale sanctie- maatregelen ). The first draft bill was published for public consulta - tion in the summer of 2024. At the time of writing, the most recent amended draft is dated 17 June 2026 (Kamerstukken II 2025/2026, 36 898, nr.7 (NvW)), and plenary debate to consider the latest amendments proposed by the Minister of Foreign Affairs has been scheduled for September 2026. Although it remains difficult to predict the precise date of enactment, the current expectation is that the International Sanctions Act will enter into force in late 2026 or early 2027. The principal elements of the proposal are outlined in the following section. Summary of the bill proposal The proposed International Sanctions Act introduces a number of significant innovations into Dutch sanctions law. Its principal purpose is not to alter the substantive legal bases on which sanctions are adopted, but to modernise the institutional and procedural framework through which sanctions are implemented, supervised and enforced in the Netherlands. In that sense, the bill seeks to render the Dutch sanctions regime more effective, flexible and future-proof. The main features of the bill, as it stands in the June 2026 version of the proposal, are summarised below. Administrative enforcement A central innovation of the bill is the introduction of administrative enforcement alongside the existing criminal law model. Under the Sanctiewet 1977, sanc - tions breaches are, in principle, addressed through criminal law: they qualify as economic offences under the Wet op de economische delicten and, where com - mitted intentionally, may be prosecuted by the Public Prosecution Service. Certain forms of administrative supervision do exist under the current framework, notably in the financial sector, but they remain con - fined to a relatively narrow category of cases. The proposed act would broaden the role of admin - istrative enforcement by permitting certain breaches to be addressed through administrative law – in par - ticular, violations of administrative obligations, such

as reporting duties, and less serious substantive infringements. It also designates certain administra - tive authorities as enforcement bodies and creates a legal basis for the designation of additional authorities where necessary. The bill proceeds from the premise that criminal law should remain a measure of last resort. Where an administrative response is more proportionate, the act would make a range of enforcement instruments available, including binding directions ( aanwijzingsbe- schikkingen ), orders subject to a penalty payment ( last onder dwangsom ), administrative fines and, in par - ticularly serious cases, the replacement of an under - taking’s board or management by a state-appointed administrator. The resulting dual-track model is best suited to cases in which the objective is to restore compliance rather than to punish, and reflects the growing scale and complexity of contemporary sanc - tions regimes. Special enforcement powers : replacing management in cases of serious non - compliance The bill further introduces an exceptional interven - tion power for cases of serious non-compliance with economic sanctions or a risk of circumvention. Where an undertaking is implicated in continuous or egre - gious sanctions violations, the Minister of Economic Affairs and Climate, acting in consultation with the other ministers concerned, may appoint one or more persons to replace the undertaking’s board or man - agement. This power is not confined to cases in which an infringement has already occurred: it may also be exercised where there is a risk of serious sanctions evasion, or where the undertaking contributes to the evasion of sanctions by associated entities. The measure is therefore both corrective and preventa - tive in character. It goes beyond ordinary supervisory and enforcement mechanisms by enabling a state- appointed administrator to assume effective control of the undertaking. The costs of the intervention may be charged to the undertaking concerned, so that they are not borne by the taxpayer. Continuity and winding - up of undertakings Another significant feature of the bill is the creation of a framework to manage the longer-term effects of asset freezes. The proposal addresses two situations:

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