Sanctions declared against Russia

What are sanctions?

Sanctions are political measures used against natural and legal persons, entities or bodies that violate international law, human rights or democratic principles. They are imposed on a country, an organisation or a person by international organisations representing a large group of countries, such as the United Nations (UN) or the European Union (EU). The Netherlands subsequently implements such sanctions pursuant to the Sanctions Act (Sanctiewet 1977 – Sw).

Sanctions against Russia

On 23 February 2022, the sanction regime concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine was changed. Restrictive measures have also been taken in response to the recognition of the non-government-controlled areas of the Donetsk and Luhansk oblasts of Ukraine, and the ordering of Russian armed forces into those areas. Click here to read the relevant legislative texts in the Official Journal of the European Union.

Within the existing framework, the restrictive measures are extended to all 351 members of the State Duma who voted on 15 February 2022 in favour of President Putin's appeal to recognise the independence of the self-proclaimed "Republics" of Donetsk and Luhansk. In addition, targeted measures are imposed on another 27 prominent persons and entities that played a role in undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. The persons and entities concerned are listed in the relevant legislative instruments in the Official Journal of the European Union. Examples of restrictive measures include freezing assets and a prohibition on making funds and economic resources available to listed persons and entities. A travel ban is also imposed on the persons listed, which should prevent them from entering or transiting EU territory.

In particular, we would like to draw attention to the new Council Regulation (EU) 2022/263. This regulation imposes restrictions on goods originating in the non-government-controlled areas of the Donetsk and Luhansk oblasts of Ukraine and on the provision, directly or indirectly, of financing or financial assistance, as well as insurance and reinsurance, related to the import of such goods. In addition, the regulation prohibits trade in goods and technology for use in certain sectors and prohibits the provision of services in the transport, telecommunications and energy sectors. The goods and technologies concerned are listed in the accompanying Annex. The regulation also prohibits the prospecting, exploration and production of oil, gas and mineral resources. Services related to tourism activities are also prohibited.

What institutions supervised by DNB must do

• Check whether these regulations apply, for example, to your customers, members or investments made.
• If they do, immediately act in compliance with the regulations’ orders and prohibitions.
• Report any funds freeze immediately to us, using the reporting form available for download on our website (Dutch only). Please email the form to us at sancties@dnb.nl. 
• If we have any questions about your report, please answer them immediately.
• A 'hit' may qualify as an unusual transaction within the meaning of the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financiering van terrorisme – Wwft). If it does, also report the transaction to FIU-the Netherlands.

This is an additional news service. Institutions remain responsible to stay abreast of and comply with sanctions legislation in a timely and accurate manner.

We also distribute regular email updates on the UN, EU and Dutch sanctions regimes. If you want to subscribe, you can sign up for our news service. We sent out an email update on 24 February. Click here to read this message (Dutch only).

The developments surrounding the situation in Ukraine are currently unfolding in rapid succession. We expect institutions to ensure they keep abreast of the latest developments. We will provide updates should the situation warrant this.