On 18 December 2023, the EU published its 12th package of sanctions targeting Russia. The changes implemented in this package have a material impact on all businesses with a continued or residual presence in Russia, including those seeking to exit and divest from Russia. Moreover, all companies, even those not trading directly with Russia, should be mindful of the increased focus on targeting circumvention.In our latest on-demand webinar, we provide you with an overview of some…
On 18 July 2023, the Dutch Fiscal Intelligence and Investigation Service (FIOD) published a statement that it had recently arrested a Dutch citizen in an ongoing investigation into suspected circumvention of EU sanctions against Russia. As part of the investigation, the FIOD also seized the business inventory and digital and physical administration of the suspect and his company. The arrested individual is suspected of exporting computers and computer parts to Russia in violation of EU sanctions.…
On 30 June 2023, the Dutch government announced supplemental controls for exports of certain advanced semiconductor production equipment from the Netherlands. These controls will enter into force on 1 September 2023. The delegated legislation, Regeling geavanceerde productieapparatuur voor halfgeleiders (the “Regulation”), is available here (in Dutch). The Regulation introduces a prior license requirement for exports of designated semiconductor production equipment items from the Netherlands to destinations outside of the European Union. Intra-Union transfers from the…
Having focused on the enforcement of sanctions by Australia, Ukraine, and Switzerland in the past weeks, we now turn our attention to the sanctions enforcement trends in the Netherlands. Recent sanctions enforcement trends in the Netherlands are mainly focused on Russia. Although the Dutch government previously already took a more restrictive (sanctions) policy position towards Russia, this is particularly the case since the Russian invasion of Ukraine last year. According to a letter to parliament of February 2023,…