How the Netherlands enforces sanctions against Russia

On May 13, 2022, Stef Blok, National Coordinator for Sanctions Compliance and Enforcement, presented a report on the implementation of sanctions against Russia to Dutch Foreign Minister Wopke Hoekstra. It analyzes cases on the implementation of sanctions restrictions and provides recommendations for the future. The full text of the final report can be read here. link.

In this article, we summarize the main findings and recommendations from this report in a concise manner.

Main conclusions 

The amount of sanctions imposed on Russia is unprecedented. The sanctions apply to almost all sectors of the Russian economy, so a large number of companies and state bodies of the Netherlands are involved in the sanctions enforcement regime. No specific information about the violation of the sanctions regime, in particular the freezing of assets of individuals and legal entities included in the sanctions list, was found.

However, now that it is becoming clear that the regime of sanctions pressure on Russia may be prolonged, it is necessary to improve control over compliance with and enforcement of sanctions.

How to improve enforcement of sanctions? 

To improve the enforcement of sanctions, Stef Blok suggests:

1. Place permanent responsibility for coordinating sanctions enforcement on the Dutch Ministry of Foreign Affairs.
2. Develop clear rules for compliance with the sanctions regime for notaries, lawyers and accountants, strengthen their responsibility for reporting. Thus, it will be impossible for them to evade responsibility for violations by invoking the duty of confidentiality adopted in these professions.
3. Within the framework of the European Union, conclude agreements that will facilitate the disclosure of information about sanctions. Specifically, to establish clear rules for adding individuals and legal entities to the sanctions list.
4. Provide a stronger legal framework for data sharing. This can be most effectively achieved by amending EU sanctions rules. If this fails, it will be necessary to amend the national legislation of the countries of the European Union.

Get more information about sanctions against Russiaintroduced for aggression in Ukraine.