UNICORN PRIVATE Sanctions compliance in the Netherlands: which rules apply and what companies must do
In short
In the Netherlands, EU sanctions regulations apply directly, together with the Sanctions Act 1977 (Sanctiewet 1977).
Breaches are punishable under the Economic Offences Act (WED), and supervisors and customs check compliance.
Companies must not make funds or goods available to listed parties and should screen clients and suppliers regularly.
Applicable rules and competent authorities
EU sanctions regulations are binding in the Netherlands without national transposition. The Sanctions Act 1977 (Sanctiewet 1977) is the national basis for applying them, and the Economic Offences Act (Wet op de economische delicten, WED) sets the criminal penalties.
De Nederlandsche Bank (DNB) and the Dutch Authority for the Financial Markets (AFM) supervise compliance by financial institutions. Dutch Customs enforce the rules on goods, and the Central Import and Export Service (CDIU) handles export licences, including for dual use goods.
Practical duties for companies
- Do not make funds or economic resources available, directly or indirectly, to persons and entities listed by the EU.
- Screen clients, suppliers, owners and banks against the sanctions lists, also when the lists change.
- Check whether your goods need an export licence, including dual use goods.
- Report frozen funds and request licences when the EU regulations require it.
- Keep records of the checks you carried out and of the decisions taken.
Fines and penalties
Statutory maximums we verified on the official texts:
- European Union, Directive 2024/1226: fines on companies of at least 5% of worldwide turnover or €40,000,000, and prison terms of at least 5 years. (source)
- Netherlands: fines on companies up to 10% of annual turnover. (source)
Maximum amounts set by law, as published by the authorities linked, checked on October 29, 2026.
Official sources
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Frequently asked questions
What is the Sanctiewet 1977?
It is the Dutch Sanctions Act, the national law that gives effect to international sanctions in the Netherlands, including EU sanctions.
How are sanctions breaches punished in the Netherlands?
Breaches are economic offences under the Economic Offences Act (WED) and can lead to fines and prison sentences. The figures we verified on the official texts are shown on this page.
Who issues export licences in the Netherlands?
The Central Import and Export Service (CDIU), part of Dutch Customs, handles export licences, including for dual use goods.
The program can make mistakes. The final responsibility for compliance stays with your company. Unicorn Intelligence is an information tool. Decisions and legal obligations, including sanctions compliance, due diligence and tender participation, remain with the customer.
Unicorn Intelligence checks your clients and suppliers against the sanctions lists every day.