Dutch technology may have been used in weapons of mass destruction

In September 2017, the head of the Dutch Military Intelligence and Security Service (MIVD), Major General Onno Eichelsheim, expressed concerns about the current lack of awareness by Dutch companies of export control regulations. Eichelsheim stated that the Netherlands is a ‘supermarket for countries that want to develop this sort of weapon’ and that Dutch companies are not sufficiently aware of the risks their business or business undertakings could be exposed to. The MIVD reportedly prevented a substantial number of foreign companies gaining access to knowledge and materials for the production of weapons of mass destruction.

As a result of these statements, the Dutch government was asked about the policy in place to prevent these technologies and materials ending up in the wrong hands. The Dutch government admitted that, in spite of the efforts made, there are still indications that Dutch technology is being used in programs for weapons of mass destruction in Iran, Pakistan and Syria. Foreign groups often use intermediaries to try and purchase these products. The government and the MIVD both stress the importance of signaling so-called ‘red flags’ and know your customer to prevent illegal and/or unwanted transactions taking place.

Criminal prosecution in the Netherlands for alleged violations of Russia sanctions

On November 9, 2017, the Dutch public prosecutor announced that it had laid charges against a Dutch freight and logistics company, asking the District Court of Amsterdam to impose a EUR 80 000 fine on the company and a two-month suspended sentence on its managing director. The company has allegedly violated EU sanctions against Russia, in place since 2014.

In March 2015, the Dutch customs authorities stopped a shipment containing parts for a radar system normally used in military aircraft, such as jet fighters. The shipment was intended for a Russian company.  The supplier was aware of this, as it had shipped the goods from Malaysia to Russia via Schiphol. EU sanctions legislation prohibit the supply of military goods to a Russian person or entity.

EU imposes arms embargo and targeted sanctions on Venezuela

On November 13, 2017, the EU published Regulation 2017/2063 imposing restrictive measures on Venezuela in light of the political instability there. The Council expressed concern about the recent elections and the democratic legitimacy of the Venezuelan government.

The EU reaffirmed that constructive dialogue and negotiation are the only sustainable way to address the crisis, but decided to adopt restrictive measures alongside its political and diplomatic efforts. The restrictive measures consist of an arms embargo, a prohibition on the export of equipment which could be used for internal repression and items used for monitoring or intercepting internet or telephone communications. The Regulation also puts in place the legal framework for asset freezes and payment prohibitions.

These sanctions are in addition to the US sanctions already imposed on Venezuela, as mentioned in our previous update.

UK publishes Sanctions and Anti-Money Laundering Bill

In preparation for life after Brexit, the UK government introduced the Sanctions and Anti-Money Laundering Bill on October 18, 2017. The new legislation will allow the UK to maintain existing sanctions currently imposed through EU law, as well as giving the UK the legal powers necessary to enable it to comply with international obligations to, for example, the United Nations.

EU expands investment ban and list of banned luxury goods for North Korea

On November 13, 2017, the EU amended its sanctions on North Korea expanding its investment ban and the list of banned luxury goods. Personal remittances to North Korea were also limited to EUR 5,000 (this had been EUR 15,000). The ban on EU investment in and/or with North Korea has been expanded to all sectors and a ban on oil exports to North Korea has also been imposed. Lastly, the list of luxury goods which are subject to an import and export ban has been updated.

EU renews listing of vessel under Libya sanctions

The EU has amended its legislation on Libya sanctions and listed the vessel ‘Lynn S’ under its Libya sanctions regime until January 29, 2018. A listed vessel is prohibited from loading, transporting, or discharging crude oil from Libya and is banned from entering EU ports. The renewal of sanctions against Libya means that EU companies with direct/indirect interests in Libya still need to act with caution when conducting business with Libyan persons or entities.


We have specialists dedicated to national and international export controls and sanctions, ensuring that we are well-placed to help understand local and global operating requirements and answer any questions you may have in this respect.

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