On 4 March 2022, the European Commission announced the introduction of the EU Sanctions Whistleblower Tool. According to the Commission, the Tool can be used to report on “past, ongoing or planned” EU sanctions violations, as well as attempts to circumvent these.

Reports to the Commission can be made either directly by email or on an anonymous basis via the online platform provided through the Tool. Submitted reports will, in the first instance, be examined by the Commission, who will conduct a preliminary inquiry. If the Commission considers that the information is credible, it will provide the anonymized report and any additional information gathered during the preliminary inquiry to the competent authorities in the relevant EU Member State(s). The national competent authorities are ultimately responsible for the enforcement of EU sanctions, and may initiate formal investigations further to the information provided to them.


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.