Sanctions 2025

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

through Turkey, Serbia, the United Arab Emirates and Kyrgyzstan. The District Court of Amsterdam found a company guilty of supplying goods and services linked to the construction of the Crimean Bridge. The case involved a breach of Council Regulation (EU) No 692/2014 of 23 June 2014, which restricts the import of goods from Crimea or Sevastopol into the EU, following the unlawful annexation of those regions. The court imposed a EUR120,000 fine on the company. Further - more, on 19 June 2025, it ordered the confiscation of EUR1,013,956, representing the total revenue earned In April 2025, the Dutch Public Prosecution Ser - vice initiated proceedings against Damen Shipyards Gorinchem and Damen Naval Shipyards for alleged bribery, forgery, money laundering and sanctions vio - lations. The investigation into the suspected sanctions breaches has been conducted primarily by customs authorities. The potential violations relate to goods and technology that may contribute to the military and technological enhancement of Russia and the development of its defence sector. The investigation remains ongoing. On 26 June 2025, the Dutch Public Prosecution Ser - vice issued news regarding criminal proceedings against a Russian national suspected of selling dual- use goods to Russia and disclosing trade secret infor - mation from the semiconductor industry to Russia. The Public Prosecution Service is seeking a prison sentence of four years. from the sanctioned activities. 3.2 Future Developments The Netherlands is in the process of reforming the current Sanctions Act 1977 in light of the increas - ing scope and complexity of international sanc - tions. The regulatory objective is to modernise the sanctions framework through the introduction of a new International Sanctions Act ( Wet internationale sanctiemaatregelen ). A pre-consultation on the draft legislation was held from 14 July to 25 August 2023, followed by a public consultation from 7 June to 9 August 2024. The International Sanctions Act draft addresses several key areas, including:

• expanded scope for administrative enforcement alongside criminal law enforcement, with enhanced provisions for information exchange; • the establishment of a central reporting point for sanctions-related notifications; • the possibility of making entries in certain public registers regarding relationships with sanctioned persons or organisations; • extension of the current administrative supervision to legal professions; and • a framework for the management and administra - tion of certain long-term frozen assets and eco - nomic resources. 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 through two routes: • before the Council, by requesting its de-listing 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 Treaty on the Functioning of the Euro - pean Union (TFEU). Its judgment may be appealed to the Court of Justice of the EU (CJEU). 4.2 Remedies De-listing challenges related to EU sanctions may result in: • the removal of the designated person from the list (since the date of the original listing or as of the re- listing date); and • damages for loss caused by the unlawful listing. 4.3 Timing Where a request for delisting is taken to court, a pro - cedure usually takes from one to two years to result in a decision. 4. Delisting Challenges 4.1 Process

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