This article provides a practical overview of the Dutch sanctions framework, the key obligations for businesses, and the enforcement trends that are shaping the landscape in 2026.
Who must comply?
The Dutch sanctions regime applies broadly. It covers all natural and legal persons in the Netherlands (including Dutch subsidiaries of foreign companies), all Dutch nationals and entities operating abroad, and all entities established under Dutch or EU law, wherever they are located, when acting within the EU.
In addition, Dutch and EU operators are expected to use best efforts to ensure that their non-EU subsidiaries do not circumvent EU sanctions. This “best efforts” obligation, set out in Article 8a of Regulation 833/2014, is increasingly under scrutiny as enforcement authorities focus on circumvention risks.
How sanctions are implemented in the Netherlands
The Netherlands implements EU restrictive measures directly. EU sanctions regulations are binding on all Member States without the need for national transposition. UN Security Council measures are also implemented, either through EU regulations or via national measures under the Sanctions Act 1977 (Sanctiewet 1977).
What makes the Dutch system distinctive is its fragmented enforcement landscape. There is no single sanctions authority. Instead, several bodies share responsibility: the Ministry of Foreign Affairs coordinates policy; the CDIU (Central Import and Export Office) handles licences and authorisations; Dutch Customs (Team POSS) supervises compliance; De Nederlandsche Bank (DNB) and the AFM oversee financial sector compliance; and the Public Prosecution Service (Openbaar Ministerie) handles criminal enforcement, supported by the Fiscal Information and Investigation Service (FIOD) in investigations.
This fragmentation is one of the issues the new Internationale Sanctiewet aims to address.
What restrictions apply?
EU sanctions cover a broad range of measures. The most relevant for Dutch businesses include asset freezes on designated persons and entities, financial restrictions (including bans on loans, investments, and financial services to targeted sectors), trade restrictions on dual-use goods, advanced technologies, energy products, and luxury goods, and sectoral measures targeting specific industries such as defence, energy, and transport.
The scope of these measures has expanded significantly since 2022, with successive Russia sanctions packages broadening both the list of designated persons and the range of restricted activities.
Licences and exemptions
Certain activities that would otherwise be prohibited can be authorised through licences issued by the CDIU. However, the grounds for exemption are strictly limited to those set out in EU law, such as humanitarian needs, diplomatic missions, and pre-existing contractual obligations.
The European Commission insists on case-by-case assessment, and general authorisations are not accepted as consistent with EU law. Companies considering a licence application should engage with the CDIU early in the process to understand the requirements and avoid delays.
Enforcement: what has changed
This is where the landscape has shifted most significantly. Dutch authorities have intensified enforcement in recent years, with notable cases including the Damen Shipyards prosecution for alleged circumvention of Russia-related sanctions, and the Dieseko settlement in 2024, where the company paid a fine and forfeited 1.6 million euros in unlawful gains for supplying restricted goods used in the construction of the Crimean Bridge.
These cases signal a clear trend: the authorities are moving beyond financial sector supervision and actively pursuing criminal enforcement across industries.
The new Internationale Sanctiewet, currently in preparation, will take this further by focusing more intensively on administrative penalties alongside criminal enforcement, expanding investigative powers, enabling management and administration of long-term frozen assets, and improving information exchange between competent authorities.
What companies should do
Given the increasing reach of sanctions regulations and the rising enforcement expectations, companies operating in or from the Netherlands should take concrete steps. Regular screening of business partners and transactions against EU and UN sanctions lists is essential. Internal compliance programmes should include clear policies, staff training, and proper record-keeping. In complex or high-risk situations, early engagement with specialist legal counsel can help assess licensing options and avoid inadvertent breaches.
For a comprehensive analysis of the Dutch sanctions regime, including a detailed discussion of the legal framework and expected legislative changes, see our contribution to the 2026 edition of the Lexology Panoramic Sanctions chapter on the Netherlands.