The Netherlands is among the countries with a high level of institutional capacity in combating financial crimes and enforcing international sanctions. Financial crimes of a transnational nature—such as money laundering, terrorist financing, and sanctions violations—are pursued in the country through both administrative and criminal mechanisms; national practices are carried out in alignment with decisions adopted by the European Union (EU) and the United Nations (UN). This structure presents an integrated system in which processes of collecting financial intelligence, analyzing it, and, when necessary, transforming it into criminal investigations complement one another. At the center of this system is the Financial Intelligence Unit – The Netherlands (FIU-NL). FIU-NL is responsible for collecting and analyzing suspicious transactions reported by banks, financial institutions, and certain professional groups. Under Dutch law, reporting suspicious transactions is regulated as an obligation. Financial institutions and certain professionals are required to submit unusual transactions or those that may fall within the scope of sanctions to the FIU. FIU-NL evaluates these notifications and, where deemed necessary, forwards them to the relevant investigative authorities. In this respect, the FIU performs a critical function in the preventive dimension of financial crimes. Moreover, the Netherlands’ active participation in international networks such as the Egmont Group enables the cross-border sharing of financial intelligence and facilitates the flow of information, particularly in crimes of an international nature such as sanctions violations.
With regard to the legal basis of sanctions, the Netherlands prefers to transpose sanctions adopted by the UN and the EU into domestic law rather than developing an independent and distinctive national sanctions regime. Within this framework, the freezing of assets belonging to individuals and entities listed in sanctions lists, the prohibition of the provision of financial services, and the restriction of certain commercial activities are directly implemented. Under the Sanctions Act in force at the national level, sanctions violations are considered economic offenses and are subject to criminal penalties. Ongoing efforts to update the existing regulation through a more comprehensive “International Sanctions Act” aim to strengthen enforcement capacity and enhance legal harmonization at the European level. In terms of criminal investigations, the Dutch Fiscal Intelligence and Investigation Service (FIOD) plays a significant role. FIOD has the authority to conduct investigations into financial crimes and sanctions violations and carries out technical examinations, particularly in cases involving complex financial structures. In recent years, investigations launched on suspicion of violations of EU sanctions against Russia demonstrate that the Netherlands not only adopts sanctions at the normative level but also enforces them effectively. Initiated investigations, imposed fines and prison sentences, and ongoing court cases reveal that sanctions violations are treated with seriousness. Arrests and search operations carried out in the Rotterdam area are among the concrete examples of these practices.
In the implementation of sanctions against Russia, companies in the Netherlands are subject to comprehensive reporting obligations. In addition to direct commercial relationships, indirect commercial connections are also subject to supervision; financial and logistical flows are examined to prevent possible circumvention of sanctions. This approach indicates that sanctions are not viewed as limited solely to explicit violations but that measures are also taken against indirect violations that may occur through complex commercial networks. Violations are assessed within the scope of economic crimes and are met with criminal sanctions. With regard to sanctions against Iran, the Netherlands implements the regulations within the framework of the UN and the EU and does not establish a separate national sanctions regime specific to Iran. The monitoring and investigation of sanctions violations concerning Iran are conducted within general sanctions oversight mechanisms. The limited availability of detailed public reports specific to Iran suggests that supervisory processes are addressed within the broader sanctions regime rather than differentiated on a country basis. This situation demonstrates that the Netherlands adopts a norm-based and framework-oriented approach in sanctions enforcement.
In the Netherlands, the obligation to report assets within the scope of sanctions constitutes another significant element. Individuals and entities included in sanctions lists are required to declare their assets within specified timeframes. Failure to fulfill this obligation may lead to legal and criminal consequences. New regulations adopted at the European Union level include steps toward defining sanctions violations as criminal offenses and harmonizing penalties; these developments directly affect Dutch practice. The suspicious transaction data included in the annual reports of FIU-NL and their sharing with law enforcement authorities enable the monitoring of the impact of sanctions on the financial system. In this context, the sanctions regime functions not only as a field of legal regulation but also as a data-based monitoring and analysis mechanism. When the monitoring of financial flows, asset-freezing decisions, and international cooperation mechanisms are considered together, it can be stated that the Netherlands has developed a high-capacity and systematic institutional structure in the field of financial crimes and sanctions.
Overall, the Netherlands has adopted a sanctions enforcement model that integrates financial intelligence, administrative supervision, and criminal investigation processes. The analytical capacity of FIU-NL and the investigative authority of FIOD complement one another, while UN and EU sanctions are directly implemented within domestic law. The intensive investigative practice observed in the context of sanctions against Russia concretizes the effectiveness of the system, while sanctions against Iran are monitored within the same institutional framework. This structure demonstrates that the Netherlands evaluates sanctions not merely as a foreign policy instrument but as a field of legal and institutional regulation aimed at safeguarding the integrity of the financial system.
Prepared by: Elif TOPAL