Implementation of sanctions against Russia and Belarus by the Netherlands

What is the Netherlands doing to implement the sanctions?

To ensure that the sanctions against Russia and Belarus are effective, everyone needs to follow the relevant rules. Financial institutions freeze assets, and companies and consumers stop buying or delivering certain goods. Various government agencies also play a part in implementing the sanctions:

• The Investment Assessment Office ensures that Dutch businesses cannot exercise rights over companies from Russia or Belarus, or receive any payments from them.
• Customs oversees the import and export of goods and checks to see whether goods are covered by the sanctions.
• The Human Environment and Transport Inspectorate oversee sanctions related to aviation and maritime affairs.
• Together with Customs, the Information and Heritage Inspectorate is responsible for controlling the import and export of art and other cultural goods.
• The Land Registry makes a note on entries for registered goods (such as real estate) that belong to individuals and entities on the sanctions list. That way, anyone consulting the registers can easily see which goods in the registry have been frozen by the sanctions.
• The Royal Military and Border Police, under the authority of the Minister of Justice and Security, guards the Netherlands’ borders. People who are subject to sanctions are not allowed into the country.
• De Nederlandsche Bank (the Dutch central bank) and the Dutch Authority for the Financial Markets oversee compliance with the rules governing the operational management of financial institutions, trusts or company service providers, and crypto providers.
• The Netherlands Food and Consumer Product Safety Authority processes applications for export licences, certifications and import inspections.
• The Public Prosecution Service investigates and prosecutes individuals and organisations that do not respect the sanctions. They work with the police, other investigative agencies and supervisory bodies.

How does the Netherlands ensure that the sanctions are followed?

To ensure that the sanctions are as effective as possible, all Dutch organisations and market participants must do their part. In addition, individuals and organisations that appear on the sanctions list are required to report any assets they have which are located in the EU. This must be done within six weeks of the day their name was added to the sanctions list. 

Reporting requirement: Central Bank of Russia reserves and assets, frozen funds and economic resources 

European Union sanctions regulations place various reporting requirements on member states in order to provide a clear picture of sanctions compliance at European level. Market participants must report the following information to the relevant government authorities.

Information on – frozen – reserves and assets of the Central Bank of Russia in the Netherlands (Art. 5a of Council Regulation (EU) No 833/2014)

Provide the required information using the European Commission form. These FAQs drawn up by the European Commission provide instructions on filling in the form.
Credit institutions should send the form to De Nederlandsche Bank (DNB).

Information on frozen funds and economic resources in the Netherlands (Art. 8 of Council Regulation (EU) No 269/2014)

Provide the required information using the European Commission form. These FAQs drawn up by the European Commission provide instructions on filling in the form. Send the form to:

• for the financial sector: The Dutch Authority for the Financial Markets (AFM) or De Nederlandsche Bank (DNB);
• for other sectors: DGBEB-Exportcontrole-ESG@minbuza.nl

The EU Sanctions Map provides links to the most recent versions of the EU sanctions regulations (under ‘Russia’ and ‘Ukraine’).

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