Sanctions 2025

BELGIUM Law and Practice Contributed by: Valerijus Ostrovskis, Bogdan Evtimov, Michael De Boeck and Coline Cauvin, ACQUIS

1.4 Overview 1.4.1 Types of Sanctions

UK, and other G7 nations. This enhanced co-ordina - tion is designed to boost the effectiveness of sanc - tions and limit the scope for sanctions evasion. Looking ahead, predicting alignment is becoming more complex, particularly as diverging US positions, after the election of the Trump administration, could weaken the EU–US–UK consensus that has shaped sanctions policy (in particular towards Russia since 2022). Use of Sanctions for Human Rights Violations Sanctions are being applied more frequently to com - bat human rights violations. The EU has utilised its Global Human Rights Sanctions Regime – also known as the “EU Magnitsky Act” – to sanction individuals and entities responsible for severe human rights abus - es. Technological and Cyber Sanctions In response to the growing cyber-threat landscape, the EU has introduced sanctions targeting cyber-attacks and the improper use of digital technologies. These measures are designed to deter both state and non- state actors from engaging in harmful cyber-activities. 1.3 Key Industries With Belgium being the centre of the EU, its jurisdic - tion has numerous sectors strongly affected by sanc - tions regulations. These include:

Belgium supports and implements UN- and G7-agreed sanctions, as well as EU autonomous designations. These include, broadly speaking: • sanctions against individuals, such as asset freez - es, travel bans under restrictive measures against third states, and horizontal sanctions regimes tar - geting violations of human rights or terrorism; and • generally applicable sectoral sanctions, prohibiting certain commercial transactions with any counter - parts from sanctioned jurisdictions or with a link to certain sectors, prohibited goods, or even sector- specific named individuals or entities. As regards Russia, Belgium and the EU have imple - mented individual sanctions on natural and legal per - sons. Belgium has also implemented sectoral sanc - tions, such as trade restrictions on several types of transactions, as well as prohibitions of certain profes - sional services. In addition, Belgium has reinforced its export control regulations on the export of dual-use goods or defence-related goods to Russia and Bela - rus. 1.4.2 Scope of Sanctions Public authorities, financial institutions, corporations, and private individuals within this scope must apply EU sanctions. Generally, EU sanctions apply broadly to all individu - als or entities within the territory of the EU. They have a wide reach and also apply: • on board any aircraft or any vessel under the juris - diction of an EU member state; • to any person inside or outside the EU who is a national of an EU member state; • to any legal person, entity or body – inside or outside EU territory – that is incorporated or consti - tuted under the law of a member state; and • to any legal person, entity or body in respect of any business done in whole or in part within the EU. However, authorities in the EU take the view that EU regulations do not provide for extraterritorial reach.

• financial services; • the energy sector; • defence and dual-use goods; • technology and telecommunications; • international trade; • maritime and shipping; • luxury goods and diamonds; and • healthcare and pharmaceuticals.

Belgium was particularly affected by the financial sanctions, owing to the presence of world-leading securities depository Euroclear. The EU’s maximum oil price and ports ban affected the ports of the North Sea. The EU diamond ban affected the Antwerp dia - mond industry hub.

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