Dutch Bill Aims to Significantly Modernize and Strengthen Sanctions Enforcement

April 10, 2026

Dutch Bill Aims to Significantly Modernize and Strengthen Sanctions Enforcement in the Netherlands

Nicolas Brice, Kevin Capatina, Ravelle Melissen, Nadiya Nychay, Elizabeth Robertson, Paloma Valor, Rick van 't Hullenaar Jones Day + Follow Contact LinkedIn Facebook X Send Embed

The proposed International Sanctions Measures Act intends to modernize the Dutch sanctions framework by significantly expanding enforcement and intervention options for sanctions violations, shifting part of enforcement to administrative law, and introducing a central reporting point in the Netherlands.

On February 19, 2026, the proposal for the International Sanctions Measures Act (Wet internationale sanctiemaatregelen, the "WIS") was submitted to the Dutch House of Representatives. As an initial step in the parliamentary process, a roundtable discussion was held in Parliament on March 25, 2026, which confirmed broad consensus about the need for the proposal.

The WIS is intended to largely replace the current Dutch Sanctions Act (Sanctiewet 1977, the "SW"). The Dutch sanctions framework predominantly consists of directly applicable EU regulations, leaving the SW to serve principally as a framework for the regulations' national implementation (e.g., licensing) and enforcement. The proposal for the WIS follows the May 2022 recommendation of the Dutch National Coordinator for Sanctions Compliance and Enforcement to strengthen the Dutch sanctions system and to ensure that legislation keeps pace with the increasing scale and complexity of international sanctions regimes.

This recommendation and the WIS are also driven by the sharp increase in sanctions activity, particularly the EU Russia Sanctions, and the Dutch government's view that effective compliance and enforcement have lagged due to limitations in the SW.

The WIS introduces several significant changes to the current framework. Most notably, it establishes new administrative enforcement powers for sanctions violations. Under the current Dutch regime, sanctions violations are penalized and enforced primarily through criminal law under the Economic Offenses Act (Wet op de economische delicten). The WIS introduces a dual enforcement system, enabling certain administrative agencies to impose designation decisions, administrative enforcement orders, and administrative fines for sanctions violations. The explanatory memorandum indicates that the Dutch legislator considers administrative enforcement more suitable for less-severe breaches, with criminal enforcement reserved as an ultimum remedium, or last resort.

The WIS also introduces powers enabling authorities to intervene directly in a company's management in certain specific situations. For Dutch-based companies where the impact of sanctions on their stability or continuity may cause serious societal, economic, or employment consequences, the Minister of Economic Affairs may appoint an administrator with powers to direct, represent or, if necessary, replace, management.

Where a company subject to a sanctions obligation is seriously noncompliant or poses a risk of serious circumvention of sanctions, including through connected companies, the Minister may appoint persons to replace management outright to ensure compliance and prevent circumvention. Additionally, for long-term frozen registered property, designated Ministers may assume or delegate management in certain specific situations, including where societal harm risks arise in relation to the registered property.

Finally, the WIS introduces measures to enhance transparency and information sharing. These include a legal basis for recording in public registers connections with sanctioned persons or entities and improved data exchange possibilities between competent authorities to map complex ownership structures and identify assets of sanctioned individuals. It also introduces a legal basis to establish a central reporting point for sanctions in the Netherlands.

The WIS must still pass both the House of Representatives and Senate before taking effect, and it may be amended during the legislative process. If adopted in its current form, it would significantly overhaul the Dutch sanctions framework, expanding the enforcement toolkit and introducing far-reaching intervention powers.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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