The Dutch FIOD has issued a press release announcing raids on business and residential premises and the arrest of two individuals aged 39 and 60.
A company, and the two individuals, are suspected of exporting sanctioned goods to Russia via third countries in breach of the EU’s sanctions.
Further to our earlier post, the prosecution trial of Damen Shipping has commenced in the Netherlands.
The company has denied the allegations, which include that it falsified customs declarations to enable the export of 14 deck cranes to Russia during 2022 in breach of the EU’s sanctions.
Senior management have also been charged with sanctions offences.
The trial includes charges of bribery against Damen.
In an investigation led by the Public Prosecutor’s Office, the Dutch FIOD last week conducted raids on two homes and arrested one individual suspected of transferring bitcoins valued at €5,000 to individuals who had joined terrorist organizations in breach of the Dutch Sanctiewet.
The transfers are said to have taken place between 2019 and 2020.
The FIOD Press release acknowledges the support of Europol in providing technical assistance and facilitating cooperation from other (unnamed) countries.
The Rotterdam District Court has issued a judgment reducing a fine of €500,000 imposed by the AFM (Autoriteit Financiele Markten) on Tradition Securities and Futures S.A. to €100,000.
The AFM had issued questionnaires in 2020, 2021, and 2022 in relation to TSAF’s compliance with Dutch AML and sanctions laws. The questionnaires were not completed.
In June 2023 the AFM notified TSAF of the intention to impose a fine of €500,000 for the failings. This was imposed in October 2023, and the judgment is the result of an appeal against both any fine and the amount of the fine.
The appeal against the fine itself was dismissed.
In relation to the size of the fine the Court ruled that the AFM failed to take note of a range of factors in its own fines guidance, namely that there was no damage to third parties, no unlawfully obtained gain, no (major) social impact, no significant scale, and no market disruption. Further it was noted that this request for information was a generic annual questionnaire and not in the context of a particular investigation or alleged breaches of sanctions. The Court was of the view that TSAF should have benefitted from a 50% reduction upon the proper application of the fining guidance but then further reduced the fine from €250,000 on the basis that such a fine was “disproportionate “not in reasonable proportion to the nature and seriousness of the violation”.
Further to our earlier post from October 2024 reporting that a company had been convicted of exporting prohibited aircraft parts to Russia and fined €165,826, a judgment published on 5 September 2025 dealt with an application to liquidate the company by the Public Prosecution Service.
The company in question has now been named as Jet Air Equipment BV.
The Gelderland Court has ordered that the company be declared prohibited and that a liquidator be appointed for the dissolution of the company. The company will have the ability to make submissions on the identity of the liquidator, but the court reserved the right to make the appointment itself.
In addition an unnamed company director has been barred for 3 years from serving as a company director.
An application to have all the assets of the company be distributed to the state was denied.
The Dutch courts have previously ordered the liquidation of a convicted company.
A civil judgement from the Amsterdam Court of Appeal has revealed the outcome of an investigation of a breach of the EU’s Iran sanctions by the Dutch authorities.
The company in question, Air Cargo Consultants BV, had acted as freight forwarder (but not the seller) for eight shipments of aircraft engines to Iran starting in 2018.
The export of these parts to Iran became newly prohibited in 2023 under EU regulation 1529/2023. The products were also barred from export to Iran under US sanctions.
On 1 October 2024 Dutch customs stopped an attempt to export a ninth aircraft engine, based on a suspicion that the products were prohibited from export to Iran under the EU’s sanctions.
On the same day that the shipment was stopped the freight forwarder self-reported all nine exports to the US authorities, namely BIS, the Office of Export Enforcement and OFAC.
The civil judgment reports that in these circumstances the Dutch authorities declined to prosecute the freight forwarder but issued a warning that any further infractions would be prosecuted.
It is unclear from this judgment what, if any action, is being taken against the seller of the engines.
The professional football club Vitesse Arnhem has been barred from the Dutch football leagues.
Further to our earlier post, the Dutch authorities and the Dutch football league have been investigating allegations that Roman Abramovich owns or controls the football club.
The football league determined, on the basis of various breaches of league rules, including the sanctions risks created by Mr Abramovich’s ownership or control of the club, to bar the club from participation in the Dutch second division.
The club sought to appeal that decision, and in a published judgment, the District Court in Midden-Nederland, has rejected that appeal.
The government’s investigation remains ongoing.
The Dutch courts have published two sanctions judgments.
In the first case, the District court of Rotterdam has sentenced an individual to three years in jail.
The individual was convicted for providing technical assistance to a person in Russia or for use in Russia of different computer files containing information on the manufacture of microchips. The files were shares by Google Drive and Telegram between January 2023 and August 2024.
The defendant was acquitted of charges of physically taking similar files to Russia on USB sticks.
On sentencing the judgment stated:
“Providing advice to and sharing technology with Russia is extremely serious. It can contribute to strengthening military or strategic capabilities of that country, which has an impact on Ukraine and can indirectly affect international security and stability. It is therefore a serious offence. … The nature and seriousness of the facts justify a prison sentence of considerable duration. The fact that the files would contain outdated information is irrelevant because this information can be of great value to a country with a (much) lower level of knowledge. It must be prevented that a country at war can benefit in any way from advanced technological knowledge. After all, for that reason, an extensive package of sanctions has also been agreed against Russia, among others“.
In the second case, the District Court of Amsterdam has issued an order confiscating €1,013,956.00.
The unnamed corporate defendant had been provided goods and services in relation to the construction of the Kirch Bridge, and had been convicted on 28 November 2024 (our previous post here), with a fine of €120,000 imposed.
The court calculated that the gross revenue obtained in breach of sanctions was €2,711,085, but allowed certain costs including internal time incurred and the cost of insurance resulting in a final confiscation of €1,013,956.
The effect of this is that revenue of nearly €1.7m obtained in breach of the EU’s sanctions was retained by the convicted company.
The Dutch FIOD has issued a press release regarding the arrest of four individuals and the launch of a criminal investigation into those individuals and an unnamed company operating in the Rotterdam area.
The individuals and company are suspected of being “involved in prohibited supplies or support of ships that are part of the so-called Russian shadow fleet” in breach of the EU’s Russian sanctions.
Raids and searches were carried out at four homes and the company’s premises.
The Nederlandsche Bank (DNB) has issued a press release relating to Erez Corporate Service B.V.
Erez was issued an “instruction” in June 2021 by the DNB in relation to the remediation of various compliance failings, including compliance with EU sanctions.
Erez has sought to challenge, and then appeal, this instruction, but those efforts have not been successful which is why the DNB are now publishing the details of the instruction.
