EU sanctions against Russia apply directly in the Netherlands and bind every business here, whatever its size. Three prohibitions do most of the work: assets of listed persons and entities are frozen; no funds or economic resources may be made available to them, directly or indirectly; and defined goods, technologies and services may not be exported, imported or supplied. A breach is an economic offence under Dutch criminal law, and it does not have to be deliberate to be punishable, although deliberate breaches are treated more severely.
The lists and sectoral measures change with each new package, so any statement of what is prohibited is a snapshot. Your obligation is therefore procedural as much as substantive: screen counterparties and their ownership against the current lists, check whether a listed person controls the counterparty, keep evidence of that screening, and repeat it during the relationship.
Table of contents
How do EU sanctions against Russia take effect in the Netherlands?
EU sanctions regulations apply in the Netherlands as soon as they are published in the Official Journal of the EU. The Sanctions Act 1977 (Sanctiewet 1977) provides the national framework, and the Public Prosecution Service (Openbaar Ministerie) can prosecute violations as economic offences.
The measures have been built up in packages since 2014 and expanded sharply since February 2022. On 23 July 2026 the Council adopted the 21st package. The economic (sectoral) sanctions have been extended until 31 July 2027, and the individual listings are reviewed and renewed every six months. This article gives an overview by sector; before any transaction, check the current text of the regulations.
Who is on the sanctions list, and what does that mean for you?
The asset-freeze list under Council Regulation (EU) No 269/2014 names individuals, companies and organisations. Their assets are frozen and you may not make funds or economic resources available to them. The 21st package alone added 216 new listings.
Check not only the name of your counterparty but also who owns or controls it. Since 2022 the list has included representatives of the Russian defence sector, persons spreading disinformation about the war, those involved in the illegal referendums in occupied parts of Ukraine, and persons who help others avoid sanctions.
Which sectors are covered by the sanctions?
The measures under Council Regulation (EU) No 833/2014 cover almost every part of trade with Russia. Below are the main sectoral restrictions as they developed since 2022.
Food and agricultural products
There is an import ban on seafood and spirits from Russia. There is also an export ban on various ornamental plant products, including bulbs, tubers, roses, rhododendrons and azaleas.
Defence and dual-use goods
The import and export of arms and related material is prohibited, and so is providing related services and support. The sale and export of civilian firearms, their essential parts and ammunition, military vehicles, paramilitary equipment and spare parts are also banned.
You may not supply certain goods, technology, technical assistance or brokering services related to dual-use goods: goods with a normal civilian use that can also serve military purposes. The list of dual-use items has been extended several times, for example with electronic components and chemicals.
Energy sector
New investments in the Russian energy sector are prohibited. This covers exploration, production and distribution within Russia of oil, gas and solid fossil fuels, refined products, and facilities for power generation.
There are far-reaching export restrictions on equipment, technology and services for oil refining, deepwater and Arctic oil exploration and shale oil projects. The purchase, import and transfer of seaborne crude oil and certain petroleum products from Russia into the EU is prohibited.
Financial sector
You may not provide loans, investment products or financial services to the Russian government, the Russian central bank or related persons and entities, and trading in their securities is prohibited. Several Russian banks have been disconnected from SWIFT. The 21st package extended the transaction ban to 33 further Russian banks and 17 further crypto-asset platforms and banks, including entities outside Russia.
Industry and raw materials
An import ban applies to products such as cement, fertiliser, fossil fuels, jet fuel and coal. Later packages extended it to steel products, wood pulp, paper, plastics, elements for the jewellery industry, cosmetics and cigarettes. Certain machinery may not be exported to Russia.
Transport
The supply of aircraft parts, repairs, related financial services and other aviation goods is prohibited, and EU airspace is closed to Russian aircraft. Russian and Belarusian road transport companies may not carry goods by road within the EU, with exceptions for medical, agricultural and food products and humanitarian aid. Russian-flagged ships are denied access to EU ports, and transactions with the Russian Maritime Register of Shipping are prohibited.
Media, luxury goods and crypto-assets
The broadcasting licences of several Kremlin-backed media outlets have been suspended in the EU. The sale and export of luxury goods to persons in Russia, or for use in Russia, is prohibited. You may not provide crypto-asset wallet, account or custody services to Russian nationals or residents, regardless of the value of the assets.
How does the oil price cap work?
EU operators may not provide maritime transport of Russian crude oil and petroleum products to third countries, or related technical assistance, brokering or financing, unless the oil was bought at or below the price cap. The cap has applied since December 2022 for crude oil and since February 2023 for petroleum products.
The cap is no longer a fixed amount: an automatic adjustment mechanism was introduced later. Under the 21st package (Council Regulation (EU) 2026/1848) the cap for crude oil stays at USD 44.10 per barrel and automatic adjustment is suspended until July 2027. If you ship, insure or finance oil cargoes, check the cap on the date of the transaction and keep the price attestations.
Which business services may you no longer provide?
Article 5n of Council Regulation (EU) No 833/2014 prohibits a range of business services to the Russian government and to entities established in Russia. These include accounting, auditing, bookkeeping, tax consulting, business and management consulting, public relations, and, after later packages, IT consultancy and cloud-related services.
Legal advisory services
Legal advice to the Russian government and to entities established in Russia is prohibited. Representation in judicial or arbitral proceedings, and preparing documents for such proceedings, are not covered. If you are a lawyer with a Russian client, consult the Netherlands Bar (Nederlandse Orde van Advocaten) and your local dean (deken) before you start.
Architectural, engineering and IT services
Architectural and engineering services, such as construction, urban planning, technical consulting and technical testing, may not be provided to Russian entities. There is an exception for technical assistance relating to goods whose export to Russia is not itself prohibited. IT consultancy, including software development and implementation for a client, is also banned under Article 5n.
Are there any other restrictions?
Yes. EU nationals and EU residents may not hold posts on the governing bodies of certain Russian state-owned companies. The import ban that first applied to the non-government-controlled areas of the Donetsk and Luhansk oblasts now also covers those areas of the Zaporizhzhia and Kherson oblasts.
Exceptions or licences are possible under certain conditions, for example for humanitarian purposes or to wind down existing contracts. Whether one applies depends on the precise wording of the provision and often requires prior authorisation from the competent Dutch authority before you act.
What should you check as a business?
Treat sanctions compliance as an ongoing process rather than a check at onboarding. Because a breach does not need to be deliberate, your records are your main defence.
- Screen counterparties, their shareholders and ultimate owners against the current EU lists.
- Check whether a listed person controls the counterparty, even where it is not named.
- Check whether your goods, technology or services fall under a sectoral ban or the dual-use rules.
- Keep a written record of each check and repeat it during the relationship.
- Build sanctions clauses into contracts so you can suspend or terminate if a counterparty is listed.
- Check whether an exception or licence applies before you perform, not afterwards.
What can we do for you with EU sanctions against Russia?
We advise businesses on sanctions compliance as part of our work as corporate lawyer; concretely:
- We check a specific transaction or counterparty against the current sanctions regulations.
- We assess whether your goods or services fall under Regulation (EU) No 833/2014.
- We draft sanctions clauses for your supply, distribution and service contracts.
- We review your screening procedure and record-keeping.
- We assess whether an exception applies and prepare a licence application.
Summary
- EU sanctions against Russia apply directly in the Netherlands; violating them is an economic offence under the Sanctions Act 1977.
- Assets of listed persons are frozen and you may not make funds or resources available to them, directly or indirectly.
- Sectoral bans cover goods, energy, finance, transport, crypto-assets and business services such as legal, IT and engineering advice.
- The rules change with every package; the 21st package dates from 23 July 2026, so always check the current text.
- Screen counterparties and their ownership, keep evidence, and repeat the check during the relationship.
Frequently asked questions
Do EU sanctions apply to a small Dutch business?
Yes. EU sanctions regulations apply directly to every person and business in the Netherlands, whatever its size, and a breach is an economic offence under the Sanctions Act 1977.
Is a company owned by a listed person also covered?
Yes, if the listed person owns or controls it. Making funds available to such a company can count as indirectly making them available to the listed person, so screen ownership as well as names.
Can I still finish an existing contract with a Russian party?
Only if a wind-down exception in the relevant regulation applies, often with prior authorisation from the competent authority. Check the precise provision before you perform.
