This year sanctions compliance became an even more essential issue for business. On a global scale, companies involved in international trade and cross-border services as well as other enterprises, certification authorities and banks face the necessity to gain more knowledge on a growing number of sanctions.
At the EU level, every few months a list of legal entities and individuals subject to sanctions, import and export bans, restrictions on the provision of certain types of services in relation to business relations between the EU and Russia is supplemented.
Also, US law provides for the opportunity to impose secondary sanctions on those who assist sanctioned companies and individuals, putting at risk a wider business community.
Sanctions law is a rapidly changing area of law, where little guidance is available at the moment and where the stakes are high. The penalty for management of the company for violation of EU sanctions in the Netherlands may be up to six years in prison, even apart from reputational risks.
When interpreting the provisions of EU sanctions law, it is important to bear in mind that those are aimed at broader coverage. This approach has also been confirmed in a few Dutch court cases.
It is crucially important for business to establish an internal screening and risk assessment mechanics and to have a reliable advisor to consult with.
Our team will be happy to assist with advice on EU financial sanctions, including but not limited to, currently allowed activities, when doing business with Russia (goods, services), initial sanctions screening, preparation of requests to RVO relating to EU sanctions in the Netherlands, etc.
Useful link for the initial check: Consolidated list of persons, groups and entities subject to EU financial sanctions - Data Europa EU