Complying with the Sanctions Act

Are you a financial service provider or do you own an investment firm in the Netherlands? For example, a bank, insurance company, (money) exchange organisation, pension fund, trust office or leasing company? You must check if any national or European sanctions have been imposed on your client. For instance, because your client is a money launderer or finances terrorism. If this is the case, you must carry out this penalty. This is stated in the Sanctions Act.

The Dutch Authority for Financial Markets (AFM) and the Netherlands Central Bank (DNB) monitor if you comply with the sanction regulations.

Carrying out sanctions

There are several institutions that can impose financial sanctions (penalties):

• the United Nations’ Security Council (UN) (the highest authority)
• the European Union (EU)
• individual countries

You have to carry out international sanctions. This means that, if for instance the UN Security Council imposes a sanction on your client, you must:

• freeze the funds of the individual or organisation
• no longer supply financial means to this individual or organisation
• no longer provide them with financial services

Checking customers against the list of sanctions

You must check if your clients are listed on:

• the European list of sanctions
• the national terrorism list
• the UN Security Council sanctions list

You perform this check at different times:

• when an individual or organisation wishes to become your client (investigating clients)
• you need to check regularly if your client is listed on 1 of the lists

Is your client on 1 of these lists? Or is your client affiliated with an organisation on the list? You are not allowed to offer this client financial services. You must carry out the sanction and notify the AFM.

You can subscribe to DNB's Dutch-language news service to receive current information on European and national sanctions (fill in the required fields, scroll down to Publicaties, tick the box Nieuwsbericht Sancties and click Aanmelden).

Reporting to AFM and FIU

Is your client on 1 of the sanctions lists? Or will you client be listed? You must report this to the Dutch Authority for Financial Markets (AFM).

Do you find out about a (proposed) transaction with a client on a sanctions list? In specific cases you must report this to the Financial Intelligence Unit – The Netherlands.