BELGIUM Trends and Developments Contributed by: Valerijus Ostrovskis, Bogdan Evtimov, Michael De Boeck and Coline Cauvin, ACQUIS
cial national competent authority in relation to dero - gations for asset freezes on securities frozen in Euro - clear. In 2024, the EU authorised the use of windfall profits generated from frozen Russian central bank assets held at Euroclear to fund Ukraine’s reconstruc - tion. This sets a significant precedent, with far-reach - ing political and legal implications, as it may lead to further pressure on Belgium to maintain high transpar - ency and reporting standards in financial services and asset management. Moreover, sectors such as maritime shipping, luxury goods (notably diamonds), and energy continue to be particularly exposed to new designations and trade restrictions. Antwerp’s diamond trade has already seen multimillion-euro seizures related to Russian- origin stones, and ports in the North Sea have been affected by bans on certain Russian-linked vessels and cargoes. Global Alignment and Emerging Divergences While the EU remains aligned with key partners such as the United States and the United Kingdom, new diver - gences are emerging. The return of a more unilateralist US administration has led to differing approaches to Russia, China, and Iran. This complicates cross-bor - der compliance strategies for multinational companies operating across both EU and non-EU jurisdictions.
For example, the EU has increasingly listed Chinese companies for facilitating circumvention, a step that the USA had taken earlier. However, EU enforce - ment standards and licensing frameworks remain less formalised than those of the US Office of Foreign Assets Control (OFAC). Companies used to operat - ing with OFAC guidance may need to adjust to the more decentralised, member state-driven nature of EU sanctions enforcement. Outlook for 2025 and Beyond At the time of writing, the EU is preparing its 18th sanctions package against Russia, which is expected to include stricter restrictions on the energy sector and financial institutions, as well as new measures addressing circumvention. These developments point to an ongoing shift from reactive listing to proactive enforcement and compliance deterrence. Looking ahead, companies should expect continued complexity and fragmentation in sanctions policy, both within the EU and globally. The trend is moving toward sectoral and behavioural sanctions, targeting specific conduct (such as circumvention) and using indirect pressure to shape business practices beyond the EU’s borders. For companies doing business in or through Belgium, this means compliance must remain high on the agenda.
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