Netherlands – Page 2 – European Sanctions Enforcement

September 8, 2025September 8, 2025 by Mark Handley

Netherlands – declination for export in breach of Iran sanctions

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.

August 13, 2025August 13, 2025 by Mark Handley

Netherlands – sanctions lead to professional football club being barred from Dutch leagues

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.

July 10, 2025July 10, 2025 by Mark Handley

Netherlands – two sanctions judgments: i) individual given 3 years prison sentence; and ii) confiscation of €1m in unlawful profits

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.

July 4, 2025July 4, 2025 by Mark Handley

Netherlands – arrests and raids in sanctions investigation into alleged supplier to the “shadow fleet”

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.

June 11, 2025June 11, 2025 by Mark Handley

Netherlands – DNB issues instruction to trust office regarding sanctions compliance

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.

May 27, 2025May 27, 2025 by Mark Handley

Netherlands – prison sentence for breaching Russian sanctions nearly doubled on appeal

Further to our earlier post that the Dutch Public Prosecution Service had brought an appeal seeking to extend an 18-month prison sentence for exporting sanctioned goods to Russia, the Court of Appeal in The Hague has now issued its judgment.

While most of the judgment relates to the issue of the amount of the “proceeds of crime” to be confiscated from the convicted defendant (reducing the level of confiscation from €72,697.71 to €71,582.95), the custodial sentence was also increased to detention for 1080 days, which is just under the 3 years sought by the Prosecution.

May 1, 2025May 1, 2025 by Mark Handley

Netherlands – appeal brought to increase 18 month sentence for Russian exports

In an earlier post, we reported on the October 2023 sentence of an individual to 18 months in jail, and a fine of €200,000 imposed on the company operated by the individual.

It is now being reported that an appeal has been brought by the Dutch Public Prosecution Service (the “OM”) seeking to increase the sentence.

The OM are seeking a three-year custodial sentence, a five-year ban from the individual acting as a director, and confiscation of €72,697.71 of the proceeds of the sanctions breaches.

It is reported that the appeal is based on the deliberate nature of the offending with the export of sanctioned goods to Russia via third countries including the Maldives and Kazakhstan.

There is no appeal in relation to the fine of €200,000 imposed on Woerd-Tech BV.

April 25, 2025April 25, 2025 by Mark Handley

Netherlands – prosecution of shipbuilder for alleged exports to Russia

The Dutch Public Prosecution Service has announced that it has charged the Dutch shipbuilding company Damen with an offence under the Dutch Sanctiewet. Other (non-sanctions) offences are also alleged.

The alleged breach of sanctions is said to have taken place in 2022 and to have involved exports to Russia of goods and technology.

The company has issued its own release which states in part:

“With regard to the suspicion of violating the Sanctions Act, Damen can report that it has always acted in accordance with the applicable sanctions packages and that full transparency has been exercised about its activities. Damen is therefore surprised that one case from June 2022 is now being submitted to the court. This is a case involving the supply of a very limited number of civilian cranes to Russia. This delivery took place within the sanctions legislation in force at the time”.

April 22, 2025April 22, 2025 by Mark Handley

Netherlands – timber confiscations from companies already under investigation for alleged sanctions violations

As reported in our post from June 2024, at that time the Dutch FIOD conducted raids and arrested two individuals suspected of importing Russian-origin timber in breach of the EU’s sanctions.

FIOD has now announced a further round of seizures from the same companies. The allegation is that the companies have continued to trade in Russian timber during the pendency of the ongoing investigations into their activities.

April 2, 2025April 2, 2025 by Mark Handley

Netherlands – person arrested on suspicion of terrorist sanctions breaches

The Dutch FIOD, has issued a press release regarding its arrest of a 32-year old man suspected of violating the Dutch Sanctiewet 1977 through the suspected transfer of bitcoins to sanctioned terrorist organisations between 2020 and 2022.

The investigation was commenced as a result of a suspicious activity report made by a crypto exchange to the Dutch FIU.