BELGIUM Law and Practice Contributed by: Valerijus Ostrovskis, Bogdan Evtimov, Michael De Boeck and Coline Cauvin, ACQUIS
ACQUIS Rue du Trône 98, 1050 Brussels Belgium
Tel: +32 (0) 2 887 94 10 Email: info@acquislp.eu Web: acquislp.eu
1. Trends and Overview 1.1 Sanctions Market Key Developments
mark. Enforcement remains uneven across member states, but there is a clear uptick in investigations, seizures, and asset-freezing measures, particularly in jurisdictions with stronger enforcement capacity. At the same time, the focus of EU sanctions policy is diversifying. Iran has re-emerged as a priority target, following the adoption of a new sanctions regime, and enforcement attention is now also turning toward third-party entities, such as Chinese entities listed for facilitating circumvention of sanctions against Russia in the latest 16th and 17th sanctions packages. Businesses have had time to adapt or restructure in jurisdictions such as the UAE and Turkey, and some continue restricted activities through third-country channels (an issue increasingly addressed by the EU in recent sanctions packages). For EU-based com - panies, novel business models and cross-border structures carry increased circumvention risks, which the Commission and national regulators have been actively highlighting through guidance and outreach. 1.2 Key Trends Increased Use of Targeted Sanctions Belgium supports sanctions adopted at the EU lev - el. There is a significant shift towards more precise and focused sanctions targeting specific individuals, entities and sectors. This aims to reduce unintended humanitarian impact and adverse effects, while exert - ing maximum pressure on the designated targets. Co-Ordination With International Partners The EU has increasingly aligned its sanctions efforts with international partners, particularly the USA, the
The market in Belgium has been affected by EU sanc - tions developments in relation to the ongoing war in Ukraine. Between June 2024 and June 2025, the EU published six new sanctions packages impacting Russia alone. The 17th sanctions package targeting Russia was published in June 2024 and the 18th sanc - tions package is being discussed. There are also EU sanctions developments in relation to the conflict in the Middle East. The latest Russia package includes asset freeze measures targeting state actors, private companies, and individuals linked to Russia and Belarus. It also involves sectoral sanctions measures targeting critical sectors such as LNG and oil, significantly reducing Russian oil and gas exports via the EU. The authors also notice increased restrictions on technology and dual-use goods exports to hinder military and tech - nological advancements. Impact on European Companies European companies are facing higher compliance costs, operational challenges, disrupted supply chains, and significant financial losses from opera - tions in Russia and Belarus. Sanctions Sector Compared to 12 Months Ago Over the past year, the volume of compliance queries related to Russia has remained steady, but enforce - ment activity has notably increased as the Russian sanctions regime matures and crosses the three-year
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