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 that can be prosecuted in the Netherlands, and the regime is strict: a breach does not have to be deliberate to be punishable, although deliberate breaches are treated more severely.

The lists and the sectoral measures are amended regularly, in successive packages, so any statement of what is prohibited is a snapshot. The obligation on a business is therefore procedural as much as substantive: screen counterparties and their ownership against the current lists, check whether a listed person controls the counterparty even where they are not named, keep the evidence of that screening, and repeat it during the relationship rather than only at onboarding.

How do EU sanctions against Russia take effect in the Netherlands?

EU sanctions regulations have direct effect: they apply in the Netherlands as soon as they are published in the Official Journal of the EU. The Dutch Sanctions Act 1977 (Sanctiewet 1977) provides the national framework, and violating the sanctions rules is an economic offence that can be prosecuted under Dutch criminal law.

The measures against Russia have been built up in packages since 2014 and expanded sharply since February 2022. In July 2026 the Council adopted the 21st package. The economic (sectoral) sanctions have been extended until 31 July 2027. The individual listings – asset freezes, travel bans and the ban on making funds available – cover around 2,600 persons and entities and are reviewed and renewed every six months. This article gives an overview of the main measures by sector. It is not a complete list: before any transaction, you should check the current text of the regulations.

Who is on the sanctions list, and what does that mean for you?

The EU has imposed restrictions on specific individuals, companies and organisations. Their assets are frozen and you may not make funds or economic resources available to them. The list[1] has been expanded many times and is still growing. Consult the current version before doing business with a Russian person or entity, and check not only the name of your counterparty but also who owns or controls it.

The Council can also list persons and entities that help others avoid sanctions. Since 2022, the list has included representatives of the Russian defence sector, persons spreading disinformation about the war, and those involved in organising the illegal referendums in occupied parts of Ukraine.

Which sectors are covered by the sanctions?

The measures cover almost every part of trade with Russia. Below is an overview of 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, supply, transfer and export of civilian firearms, their essential parts and ammunition, military vehicles and equipment, paramilitary equipment and spare parts are also banned. In addition, you may not supply certain goods, technology, technical assistance or brokering services related to dual-use goods. Dual-use goods are goods that have a normal civilian use but can also be used for military purposes. The list of dual-use items has been extended several times, for example with certain electronic components and chemicals, to limit Russia’s military and technological capacity.

Energy sector

The energy sector covers the exploration, production, extraction and distribution within Russia of oil, natural gas and solid fossil fuels. It also covers the manufacture and distribution within Russia of products from solid fuels, refined petroleum products and gas, and the construction of facilities and the supply of services, equipment or technology for power generation and electricity production.

New investments in the Russian energy sector are prohibited. There are far-reaching export restrictions on equipment, technology and services for the energy sector, including for oil refining, deepwater and Arctic oil exploration and production, 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. Trust services to this group are also restricted. Trading in their securities is prohibited, and several Russian banks have been disconnected from the SWIFT payment system. Successive packages have added transaction bans on further banks and crypto service providers, and the 21st package (July 2026) again targeted a large number of banks and financial institutions.

Industry and raw materials

An import ban applies to products such as cement, fertiliser, fossil fuels, jet fuel and coal. Later packages extended the import ban to steel products, wood pulp, paper, plastics, elements for the jewellery industry, cosmetics and cigarettes. Large companies in the machinery sector are subject to additional sanctions, and certain machinery may not be exported to Russia.

Transport

The supply of aircraft parts, repairs, related financial services and other goods used in aviation is prohibited. EU airspace is closed to Russian aircraft, and sanctions apply to large companies in the Russian aviation and shipbuilding sectors. Russian and Belarusian road transport companies may not carry goods by road within the EU, with certain exceptions, including 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

The broadcasting licences of several Kremlin-backed media outlets have been suspended in the EU to counter propaganda and disinformation.

Art, culture and luxury goods

Goods belonging to persons on the sanctions list are frozen. The sale, supply and export of luxury goods to persons and organisations in Russia, or for use in Russia, are also prohibited.

Crypto-assets

You may not provide crypto-asset wallet, account or custody services to Russian nationals or persons residing in Russia, regardless of the total value of the crypto-assets. Recent packages have added bans on specific crypto platforms.

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, financing or financial assistance. The exception is oil 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 price cap is no longer a fixed amount. An automatic adjustment mechanism was introduced later, but under the 21st package automatic adjustments are paused until 15 July 2027. If you are involved in shipping, insuring or financing oil cargoes, check the price cap that applies 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 providing a range of business services to the Russian government and to legal persons, entities and bodies established in Russia. These include accounting, auditing, bookkeeping, tax consulting, business and management consulting, and public relations services. Other packages added further services, such as IT consultancy and cloud-related services.

Legal advisory services

Legal advisory services to the Russian government and to entities established in Russia are prohibited. This prohibition does not cover representation in, or access to, judicial or arbitral proceedings, and certain related activities such as preparing or verifying documents for such proceedings. Whether a specific assignment falls under the prohibition depends on the facts. If you are a lawyer or adviser with a Russian client, consult the Netherlands Bar (Nederlandse Orde van Advocaten) and your local dean (deken) before you start.

Architectural and engineering services

Architectural and engineering services include construction, urban planning and landscape architecture, engineering-related scientific and technical consulting, and technical testing and analysis. These services may not be provided to Russian entities. There is an exception for technical assistance relating to goods whose sale, supply, transfer or export to Russia is not itself prohibited.

IT consultancy services

IT consultancy covers advice on the installation of computer hardware and networks and on software implementation. In practice it also includes developing and implementing software for a client. These services may not be provided to Russian entities.

Are there any other restrictions?

Yes. Nationals of EU Member States and persons residing in the EU may not hold posts on the governing bodies of certain Russian state-owned companies. The geographical scope of the measures has been extended: the import ban that first applied to goods from the non-government-controlled areas of the Donetsk and Luhansk oblasts now also covers the non-government-controlled areas of the Zaporizhzhia and Kherson oblasts.

Under certain conditions, exceptions or licences are possible, for example for humanitarian purposes or to wind down existing contracts. Whether an exception applies depends on the precise wording of the relevant provision and often requires prior authorisation from the competent authority.

What should you do as a business?

Treat sanctions compliance as an ongoing process. In practice, this means:

screening counterparties, their shareholders and ultimate owners against the current lists;
checking whether your goods, technology or services fall under a sectoral ban, including dual-use restrictions;
keeping a written record of each check and repeating it during the relationship;
building sanctions clauses into your contracts, so you can suspend or terminate if a counterparty is listed;
seeking advice before you act where an exception or licence may apply.

In summary

EU sanctions against Russia apply directly in the Netherlands; violating them is an economic offence.
Assets of listed persons are frozen and you may not make funds or resources available to them, directly or indirectly.
Sectoral bans cover trade in 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 July 2026, so always check the current text.
Screen counterparties and their ownership, keep evidence, and repeat the check during the relationship.

[1] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02014R0269-20220721

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