On 22 February 2023, Dutch Customs published a press release on its website indicating that the additional EU sanctions measures against Russia and Belarus will enter into force on 24 February 2023.

Although relevant legislative texts have not yet been published, the release suggests that the “tenth package” of EU sanctions against Russia will include:

  • an extension of the export restrictions related to dual-use goods and goods which could contribute to the enhancement of Russian industrial capacities;
  • an extension of the import restrictions related to goods which may generate significant revenues for Russia and goods intended for the Russian aviation and space industry;
  • possibly, import restrictions related to diamonds.

The release further suggests that the EU will impose new sanctions against Belarus, as a result of which “the sanctions against [Belarus] will be in accordance with those against Russia.” The release does not provide further details on any specific measures.

24 February 2023 marks the one-year anniversary of the Russian invasion of Ukraine. Dutch Customs is part of the Dutch Ministry of Finance.


Derk advises clients on a wide variety of EU, regulatory and competition law matters, including merger control, cartels and vertical agreements. In addition, he advises and assists clients with respect to compliance and enforcement issues relating to EU and Dutch export controls, trade laws and sanctions. Derk has further acted for clients in various compliance investigations, both internally and involving government authorities.


Paul Amberg is a partner in Baker McKenzie’s Madrid office, where he handles international trade and compliance issues. He advises multinational companies on export controls, trade sanctions, antiboycott rules, customs laws, anticorruption laws, and commercial law matters. Paul helps clients assess and address compliance risks presented by export controls, trade sanctions, antiboycott rules, customs laws, and anticorruption laws. His practice especially focuses on internal reviews, voluntary disclosure filings, and enforcement actions brought by, the US Government in relation to the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), trade and economic sanctions programs, and US customs laws.