UNICORN PRIVATE Sanctions fines in the Netherlands: cases and penalties
Dutch decisions on sanctions breaches are published without the names of the companies: this page uses the descriptions of the source.
In short
Published cases on this page: 1. Authorities: 1. Years: 2024 to 2024.
In the United States (OFAC, BIS) and in the United Kingdom (OFSI, since 15 June 2022) civil liability is strict: a company can be fined even if it did not know that the counterparty was sanctioned.
Amounts are shown in the currency of the decision and are never converted.
Good to know
- The case of the Amsterdam company is an out-of-court settlement (transactie) with the Public Prosecution Service (Openbaar Ministerie).
Cases
Cases shown: 1 of 1
| Sector | What happened | |||||
|---|---|---|---|---|---|---|
| Amsterdam company not namedOut-of-court settlement with the prosecutor (transactie) | Netherlands | Banks and financial intermediaries | Openbaar Ministerie | €195,000 €20,000 (director) |
The company paid about €18m of dividends to a Russian shareholder behind which stood a listed person, and repaid money to an EU-listed Russian company. Official source verified on November 13, 2026 |
Select a column heading to sort the table. Amounts are shown in the currency of the decision and are never converted.
Totals by year and by authority
Sums of the amounts imposed on companies in this list, by currency, never converted. Not included: breaches published without a fine, anti money laundering penalties, confiscations and amounts imposed on individuals. A total marked about or more than includes an amount that the source gives as approximate or as a minimum.
By year
| Year | Cases | Total |
|---|---|---|
| 2024 | 1 | €195,000 |
By authority
| Authority | Cases | Total |
|---|---|---|
| Openbaar Ministerie | 1 | €195,000 |
Maximum penalties set by law
Maximums in the law, as verified on the official texts linked:
- European Union, Directive (EU) 2024/1226: each Member State must provide, for companies, maximum fines of no less than 5% of worldwide turnover or €40 million (1% or €8 million for some reporting obligations), and for individuals maximum prison terms of at least 5 years for the main offences above €100,000 and for military or dual-use goods. The offences require intent (serious negligence for military and dual-use goods). Transposition deadline: 20 May 2025. (Official source)
- Netherlands, Economic Offences Act (WED, article 6): up to 6 years in prison and a fine of the fifth category (or of the next higher category). For the transposition of the directive only a ministerial communication was found. (Official source)
Frequently asked questions
How much can a company be fined for sanctions breaches in the Netherlands?
European Union, Directive (EU) 2024/1226: each Member State must provide, for companies, maximum fines of no less than 5% of worldwide turnover or €40 million (1% or €8 million for some reporting obligations), and for individuals maximum prison terms of at least 5 years for the main offences above €100,000 and for military or dual-use goods. The offences require intent (serious negligence for military and dual-use goods). Transposition deadline: 20 May 2025. Netherlands, Economic Offences Act (WED, article 6): up to 6 years in prison and a fine of the fifth category (or of the next higher category). For the transposition of the directive only a ministerial communication was found.
Which companies have been fined in cases involving this country?
This page lists 1 published cases. The largest amounts are: Amsterdam company not named (Openbaar Ministerie, Out-of-court settlement with the prosecutor (transactie), September 23, 2024): €195,000. The case of the Amsterdam company is an out-of-court settlement (transactie) with the Public Prosecution Service (Openbaar Ministerie).
Does Dutch law require intent for sanctions offences?
Directive (EU) 2024/1226 requires intent for the criminal offences, and serious negligence is enough for military and dual-use goods. For its transposition in the Netherlands only a ministerial communication was found.
Who punishes sanctions breaches in the Netherlands?
The Public Prosecution Service (Openbaar Ministerie), which can also settle cases out of court (transactie), and the criminal courts.
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List not exhaustive, based on public official sources. Date of the last verification: November 13, 2026.
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