NETHERLANDS Law and Practice Contributed by: Sebastiaan Bennink, Nicolas Burnichon, Siqi Zhao and Daniel Webb, 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.amsterdam@benninkdunin.com
1. Trends and Overview 1.1 Sanctions Market
ness and improved internal compliance efforts, with an increasing number of Dutch companies developing policies and controls to ensure adherence to sanc - tions obligations. The Netherlands has significantly intensified its enforcement of international sanctions. The Dutch Public Prosecution Service has launched multiple investigations into sanctions violations and circum - vention efforts. In 2024 and 2025, Dutch criminal courts issued convictions in three cases involving natural persons for violating sanctions. Furthermore, the Dutch government is undertaking legislative reform of the Sanctions Act 1977 ( Sanc- tiewet 1977), aiming to replace it with a new Interna - tional Sanctions Act. This legislation will broaden the scope for administrative enforcement, complementing existing criminal measures and enhancing the overall sanctions framework. 1.2 Key Trends The main trends in sanctions in the Netherlands have been significantly influenced by developments in the EU sanctions regimes. Key trends include the follow - ing. • Enhanced enforcement of EU sanctions through multiple national enforcement authorities. • Strengthened anti-circumvention and due diligence requirements, with increased enforcement. • Expanded targeting of hybrid threats and “shadow fleet” vessels, accompanied by a growing number of designations.
Over the past 12 months, the EU has adopted its 15th, 16th and 17th sanctions packages against Russia. These successive measures have further expanded the scope of the EU’s Russia sanctions regime, tar - geting additional sectors of the Russian economy and aiming to counter ongoing circumvention efforts, including those involving the so-called “shadow fleet” used to bypass oil-related restrictions. The EU has also intensified compliance obligations under the regime, underscoring its continued commitment to the enforcement of the oil price cap mechanism and the broader prevention of sanctions circumvention. In parallel, the EU has introduced a hybrid threats sanctions regime, creating a new framework for restrictive measures in response to Russia’s desta - bilising activities directed at the EU and its member states. With regard to Syria, nearly all economic sanctions were suspended in early 2025 to facilitate humani - tarian efforts. However, certain restrictive measures remain in place on security and human rights grounds, including targeted asset freezes and an arms embar - go. 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. At the same time, there is a growing trend of heightened aware -
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