Sanctions 2025 Comparisons

Over the past 12 months, the EU has adopted its 15th, 16th and 17th sanctions packages against Russia. These successive admeasures have further expanded the scope of the EU’s Russia sanctions regime, targeting additional sectors of the Russian economy and aiming to counter ongoing circumvention efforts, including those involving the so-called “shadow fleet” used to bypass oil-related restrictions. The EU has also intensified compliance obligations under the regime, underscoring its continued commitment to the enforcement of the oil price cap mechanism and the broader prevention of sanctions circumvention.

In parallel, the EU has introduced a hybrid threats sanctions regime, creating a new framework for restrictive measures in response to Russia’s destabilising activities directed at the EU and its member states.

With regard to Syria, nearly all economic sanctions were suspended in early 2025 to facilitate humanitarian efforts. However, certain restrictive measures remain in place on security and human rights grounds, including targeted asset freezes and an arms embargo.

At the national level, the sanctions landscape in the Netherlands has continued to evolve. EU operators face increasingly complex and far-reaching restrictions stemming from the EU framework. At the same time, there is a growing trend of heightened awareness and improved internal compliance efforts, with an increasing number of Dutch companies developing policies and controls to ensure adherence to sanctions obligations.

The Netherlands has significantly intensified its enforcement of international sanctions. The Dutch Public Prosecution Service has launched multiple investigations into sanctions violations and circumvention efforts. In 2024 and 2025, Dutch criminal courts issued convictions in three cases involving natural persons for violating sanctions.

Furthermore, the Dutch government is undertaking legislative reform of the Sanctions Act 1977 (Sanctiewet 1977), aiming to replace it with a new International Sanctions Act. This legislation will broaden the scope for administrative enforcement, complementing existing criminal measures and enhancing the overall sanctions framework.

The main trends in sanctions in the Netherlands have been significantly influenced by developments in the EU sanctions regimes. Key trends include the following.

• Enhanced enforcement of EU sanctions through multiple national enforcement authorities.
• Strengthened anti-circumvention and due diligence requirements, with increased enforcement.
• Expanded targeting of hybrid threats and “shadow fleet” vessels, accompanied by a growing number of designations.
• Broader application of sectoral sanctions, affecting the defence, semiconductor and aviation industries, among other high-technology industries.
• The Dutch government is modernising the sanctions regulatory framework and proposing a new International Sanctions Act. Key elements of the proposed Act include, amongst others, the introduction of an administrative sanctions enforcement system, an updated central reporting point, the ability to annotate public registers with information concerning relations with sanctioned persons, extended supervision of the legal professions and enhanced management of long-term frozen assets and economic resources.

Many economic sectors are impacted by the broad scope of sanctions measures. In the Netherlands, the following industries are particularly affected:

• the sensitive technology industry – specifically the semiconductor, quantum technology and AI technology sectors;
• the defence industry;
• the shipbuilding industry;
• the logistics and transport industry;
• the financial sector;
• the luxury goods industry;
• the energy industry;
• the metals and raw materials industry; and
• companies engaged in activities involving dual-use and/or military items.

Implementation of Sanctions in the Netherlands

In the Netherlands, the implementation and administration of sanctions are governed by the Sanctions Act 1977. Sanctions are primarily implemented by the Ministry of Foreign Affairs in co-ordination with other ministries that are responsible for specific measures, depending on their area of competence.

Key ministries involved

The following ministries play a central role in the domestic implementation of international sanctions:

• Ministry of Finance – responsible for provisions relating to the financial sector and financial transactions; and
• Ministry of Infrastructure and Water Management – oversees provisions concerning transport infrastructure, including roads, railways, waterways and airways, with a particular focus on Dutch ports.

Other relevant ministries and authorities

A number of other ministries and agencies are responsible for implementing sanctions-related measures within their areas of competence:

• Ministry of Economic Affairs – focuses on issues relating to economic competitiveness and trade;
• Ministry of Education, Culture and Science – responsible for education, cultural development, cultural heritage and scientific research;
• Ministry of Climate Policy and Green Growth – handles matters related to the energy sector;
• Ministry of Agriculture, Fisheries, Food Security and Nature – oversees sustainable food production, environmental protection and rural development;
• Ministry of Housing and Spatial Planning – responsible for housing policy and the release or provision of economic resources connected to real estate;
• Ministry of Justice and Security – ensures the enforcement of legal measures and upholds the rule of law in the context of sanctions;
• National and International Road Transport Organisation (Nationale en Internationale Wegvervoer Organisatie; NIWO) – responsible for the licensing of road transport operators; and
• Human Environment and Transport Inspectorate (Inspectie Leefomgeving en Transport; ILT) – oversees access for ships entering Dutch waters and aircraft seeking entry into Dutch airspace.

Reporting obligations differ depending on the sanctions framework and the applicable sanctions. Financial institutions are particularly subject to such obligations. In general, operators are also required to report their use of exemptions, directly by means of reports or indirectly through the notification of their use. Designated persons and entities listed in Annex I shall report any assets and property they own in EU countries within six weeks of being added to the list. Such designated individuals and entities are to report via a special form sent by mail.

Dutch authorities have intensified efforts to enforce sanctions, with a particular focus on prosecuting violations and addressing circumvention schemes.

In September 2017, the Dutch Public Prosecution Service initiated a criminal investigation into the involvement of several Dutch companies, including Dieseko, in the construction of the Crimean Bridge in Russia. The investigation found that Dieseko had breached sanctions by selling prohibited goods and providing technical assistance in relation to the supplied products. In July 2024, the case was concluded by way of a settlement agreement, which included both a financial penalty and a confiscation component.

In 2024, Dutch courts delivered judgments in two cases resulting in the conviction of natural persons. On 17 October 2024, the District Court of Rotterdam convicted a Russian national residing in the Netherlands and imposed a custodial sentence of 450 days, of which 344 days were conditional, minus time spent in pre-trial detention. The sentence also included a probation period of two years and a community service order of 240 hours – or 120 days’ imprisonment. The conviction related to the supply and export to Russian companies in Russia – via transit countries – of electronic dual-use goods and technology, certain luxury items and goods capable of contributing to the enhancement of Russia’s industrial capacity.

On 22 November 2024, the District Court of Rotterdam convicted a natural person of a prison sentence of 300 days, of which 195 days were conditional, minus pre-trial detention with a probation period of two years, and a community service order of 240 hours – or 120 days’ imprisonment. This individual, together with his accomplices, supplied aviation components to a company in Russia through circumvention routes 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. Furthermore, on 19 June 2025, it ordered the confiscation of EUR1,013,956, representing the total revenue earned from the sanctioned activities.

In April 2025, the Dutch Public Prosecution Service initiated proceedings against Damen Shipyards Gorinchem and Damen Naval Shipyards for alleged bribery, forgery, money laundering and sanctions violations. 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 Service issued news regarding criminal proceedings against a Russian national suspected of selling dual-use goods to Russia and disclosing trade secret information from the semiconductor industry to Russia. The Public Prosecution Service is seeking a prison sentence of four years.

The Netherlands is in the process of reforming the current Sanctions Act 1977 in light of the increasing scope and complexity of international sanctions. 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 administration of certain long-term frozen assets and economic resources.

In relation to EU sanctions, designations of persons and entities are made by the European Council. Consequently, 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 European Union (TFEU). Its judgment may be appealed to the Court of Justice of the EU (CJEU).

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.

Where a request for delisting is taken to court, a procedure usually takes from one to two years to result in a decision.

Certain EU sanctions regimes contain multiple import and export bans on services to or from other countries, including:

• technical assistance, brokering services or financing or financial assistance related to prohibited exports of goods;
• reloading services to certain ships;
• services related to liquefied natural gas projects;
• investment services;
• banking services;
• specialised financial messaging services;
• credit rating services;
• accounting, auditing, book-keeping, tax consulting, business and management consulting or public relations services;
• construction, architectural and engineering services;
• legal advisory services;
• IT consultancy services; and
• market research and public opinion polling services.

Certain EU sanctions regimes include multiple import and export bans on goods to or from other countries, such as:

• arms and dual-use items, as well as advanced goods and technologies;
• oil and gas goods, technologies and products;
• aviation and space goods and technologies;
• iron and steel products;
• luxury goods, gold, diamonds and jewellery;
• goods that generate significant revenue for Russia;
• goods that could specifically contribute to the enhancement of Russian industrial capacities;
• crude oil and petroleum products;
• liquified natural gas; and
• cultural properties.

In some EU regulations, provisions exist that prohibit certain parties from making a claim where the performance of a contract has been affected, directly or indirectly, by the sanctions measures imposed in that Regulation. Examples of these are Article 11 of Regulation 833/2014 and Regulation 269/2014, as well as Article 8d of Regulation 765/2006 and Article 10 of Regulation 2022/263. Where these provisions apply, there is naturally no need to consider the application of force majeure as a claim would be struck out on the basis of these provisions.

More generally on force majeure, there is no specific provision of Dutch law focused on the legal effect of sanctions on the performance of contractual obligations. In general civil law, Article 6:75 of the Dutch Civil Code states that a party is not liable for a breach of contract if they are not at fault, personally or by virtue of the law.

If sanctions make it impossible to perform the contract, then force majeure could theoretically be invoked under Dutch law. In practice, however, the courts are not typically willing to accept its invocation. Judgments of the courts show that there is a high threshold for the invocation of force majeure if it is still somehow possible to fulfil obligations under the contract and the courts appear unwilling to make the creditor share in the risk that was in the sphere of the debtor. For example, the courts have not accepted the argument that a failure to receive money from Libya due to EU sanctions constitutes force majeure in relation to a business lease where that money was needed to pay the rent; and neither did the courts allow an entity that found itself unable to supply a specific product to an Iranian entity due to US sanctions to invoke force majeure, as it argued that products could instead be procured from a different country that fell outside the scope of US sanctions. Nevertheless, in one proceeding, the Amsterdam District Court did accept the invocation of the parties’ contractual force majeure clause where the specifically designed product could not be sent to the client due to sanctions-related export restrictions.

The authors are not aware of any public court judgments regarding the enforcement of judgments where sanctions issues arise.

Depending on the source of the sanctions regime, designation is decided by:

• the EU Council (for EU sanctions); or
• the Dutch Minister of Foreign Affairs (for the national terrorism sanctions list). 

EU restrictive measures, particularly Regulation 269/2014 regarding Russia, provide that “all funds and economic resources belonging to, or owned, held or controlled by sanctioned natural and legal persons shall be frozen”, which presumably includes the controlled or owned assets of companies owned or controlled by the designated person or entity, according to the Commission frequently asked questions (FAQs).

Guidance was given by the Council on its best practices for the effective implementation of restrictive measures.

• Ownership means the possession of 50% or more of the proprietary rights of an entity or having majority interest in it.
• Control includes:
1. having the right or exercising the power to appoint or remove a majority of the members of the administrative, management or supervisory body of such legal person or entity;
2. having appointed, solely as a result of the exercise of one’s voting rights, a majority of the members of the administrative, management or supervisory bodies of a legal person or entity who have held office during the present and previous financial year;
3. controlling alone, pursuant to an agreement with other shareholders in or members of a legal person or entity, a majority of shareholders’ or members’ voting rights in that legal person or entity;
4. having the right to exercise a dominant influence over a legal person or entity, pursuant to an agreement entered into with that legal person or entity, or to a provision in its memorandum or articles of association, where the law governing that legal person or entity permits its being subject to such agreement or provision;
5. having the power to, de facto, exercise the right to exercise a dominant influence, as referred to in the preceding bullet point, without being the holder of that right;
6. having the right to use all or part of the assets of a legal person or entity;
7. managing the business of a legal person or entity on a unified basis, while publishing consolidated accounts; and
8. sharing jointly and severally the financial liabilities of a legal person or entity, or guaranteeing them.