News item | 22-04-2022 | 09:26
The government believes it is important that the EU sanctions against Russia be as effective as possible. And that the Netherlands fully complies with and enforces these sanctions. In a letter to the House of Representatives, Minister Hoekstra of Foreign Affairs shares the latest developments.
Dutch compliance with the sanctions
Since the beginning of the war in Ukraine, the cabinet has made efforts to implement and enforce the sanctions. In the meantime, for example, € 632.9 billion in assets of persons and entities on the sanctions list has been frozen†† And Customs has detained twenty ships.
| * What are frozen funds and assets? If funds (money) are frozen, an affected person, organization or company will no longer be able to withdraw or transfer the funds. If assets such as real estate or ships are frozen, they may no longer be sold, traded or used as collateral. Property cannot be seized or expropriated by Dutch authorities. |
Overview of sanctions compliance in the Netherlands
As of April 21, 2022, this was the state of play for sanctions compliance:
| Category | Result compliance |
|---|---|
| Financial assets | €632.9 million frozen |
| Transactions | €274.3 million frozen |
| Vessels | 20 vessels in the picture |
| Airplanes | 1 on the ground, 5 ‘wrapped up’ |
| freight | 33,500 containers checked |
| Property | No signals |
How has the Netherlands acted in complying with sanctions?
The overall picture is that proper action has been taken in compliance with sanctions in the Netherlands. By entrepreneurs and companies, financial institutions, regulators and implementing organisations. The picture that is sometimes painted that billions of assets of sanctioned Russian parties are located in the Netherlands, or that billions have been leaked because the Netherlands acted too late, does not correspond to reality. According to the government, there are a number of important points for attention:
- there are no indications that large-scale assets were funneled out of the Netherlands after the sanctions were imposed. If so, it is a criminal offence. A number of possible violations are being investigated.
- it is possible that certain properties of sanctioned persons or legal entities are difficult to find in the Netherlands, because their possession has been deliberately made complex. A data team is investigating such assets. And checks whether these can be linked to persons on the sanction list.
- sometimes it can appear on paper that certain assets are in the Netherlands. But in reality, those assets are abroad. That can be done using trust services† The provision of trust services to Russian persons and entities on the sanctions list has been banned.
Next steps sanctions
Stef Blok has been coordinating the Dutch implementation of the sanctions and their supervision since 4 April 2022. With the relevant authorities, he is looking at possibilities to reduce the risk of assets being diverted before sanctions come into effect. Also for the future.
There is little chance that there is as yet unfrozen assets of persons and entities on the sanction list in the Netherlands. However, the cabinet is checking whether things have been missed. To this end, for example, the exchange of data between the various authorities involved has been made possible. The amount of frozen assets is not expected to increase much further in the coming period. Unless more persons or entities are added to the sanctions list.
International comparison: results of the Netherlands and other EU countries
According to the European Commission, €29.6 billion in assets has been frozen by the EU member states that reported on it. So far, more than half of the Member States have done so. There is therefore no complete and detailed overview. That is why it is sometimes unclear what countries do and do not count. Of the €29.6 billion, according to the Commission, about €6.7 billion consists of real estate, boats, aircraft and art.
The letter to parliament contains an overview of the frozen assets and blocked transactions in various EU member states. The figures come from (news) sources or reports from the countries.
More about the letter to parliament
The letter to parliament of April 21, 2022 also discusses other sectors that fall under the sanctions. For example, there is more information about developments in the field of:
- shipping
- aviation
- road transport
- nuclear transport
- freight
- art
- company property