Sanctions law and screening.
The Dutch Sanctions Act 1977 (Sw) requires financial institutions to screen relationships and transactions continuously against the applicable sanctions lists, freeze hits and report them to DNB without delay. The AFM and DNB supervise via the Sanctions Act Supervision Regulation (Rtsw). Unlike the Wwft, compliance cannot be “switched off” on a risk basis: continuous screening is a hard requirement. Below: scope, the concept of a “relationship”, the 50% rule, transaction filtering and the reporting procedure.
Status · last updated 7 October 2026.
What we do for you.
Three ways we help you with sanctions screening.
Policy, screening of relationships and transactions, the 50% rule and the set-up of alerts and handling.
Reporting hits and frozen assets to DNB or the AFM, and preparing the annual sanctions report.
Assessment of lists, thresholds, fuzzy matching and record-keeping against supervisory expectations.
Frequently asked questions.
What does the Sanctions Act 1977 govern?
The Sanctions Act 1977 is the national basis for implementing international sanctions in financial transactions. EU regulations and national rules distinguish three types of financial sanction: an obligation to freeze the funds and assets of designated persons or entities, a prohibition on making funds available to them directly or indirectly, and a prohibition or restriction on providing financial services.
Who supervises, and on what basis?
For financial transactions the AFM and DNB supervise compliance with the Sw. Together they adopted the Sanctions Act Supervision Regulation (Rtsw), which requires institutions to take measures to check whether relationships appear on one or more sanctions lists: EU decisions and regulations, the national Terrorism List (Sanctions Regulation Terrorism 2007-II) and UN Security Council resolutions.
Can sanctions compliance be applied on a risk basis?
No. An institution must be able to detect continuously whether its relationships appear on the lists — or whether its services and transactions relate to them — and inform DNB without delay under Article 3 Rtsw. This requirement cannot be applied on a risk basis: an institution cannot choose whether to comply and skip continuous screening. A risk assessment is, however, needed before designing the measures (for example within the SIRA).
What counts as a “relationship”?
The Rtsw uses a broad definition: anyone involved in a financial service or transaction. This includes clients, representatives and authorised agents, UBOs, beneficiaries of a product or transfer, the counterparty to a transaction, and directors of clients and related parties. The broad scope follows from the fact that both direct and indirect provision of funds or services falls under the sanctions.
What is the 50% / control rule?
Making funds available to a person or entity that is not itself listed, but is 50% or more owned by — or under the control of — a sanctioned person, counts as indirectly making funds available to that sanctioned person (EU guidelines 2013). If the 50%+ owner or controller is listed, the entity’s funds must also be frozen and nothing may flow to it. Because control does not require a 50% stake, in practice institutions also map UBOs below 50% (often from the Wwft threshold of 25%).
How does transaction filtering work?
In transactions the parties involved are screened against the sanctions lists. The minimum fields filtered are originator, beneficiary, place names, country and description. Payment institutions filter the SWIFT MT series and fields (including n99) and SEPA messages, based on a documented risk assessment. Internal controls are designed so that compliance is also ensured for payments routed via third parties.
What must be reported to DNB on a hit?
On a genuine hit the institution freezes the funds and reports immediately to the supervisor using the AFM/DNB reporting format: identifying data (name, alias, place of residence and birth, date of birth), the nature and size of the frozen funds or assets, the action taken and the applicable sanctions regime(s). False positives are not reported; in case of doubt the institution first investigates further. An existing client may not be “offloaded” — where applicable an exemption can be requested from the Ministry of Finance.
How does this interact with a Wwft report, and what is the retention period?
When an institution freezes on the basis of a hit, it also reviews the transaction history for signs of money laundering or terrorist financing; on suspicion a report follows to the FIU under Article 16 Wwft. Funds remain frozen until the sanctions regime changes, an exemption is granted, or the Minister/DNB notify otherwise. Reported data are kept until five years after the relevant sanctions regime ceases to apply.
Is the Dutch Sanctions Act 1977 being replaced?
Yes. On 17 February 2026 the bill for the International Sanctions Measures Act (Wet internationale sanctiemaatregelen) was submitted to the Dutch House of Representatives (file 36898), replacing the Sanctions Act 1977. Core elements: administrative enforcement alongside criminal law, a central sanctions reporting point, better legal bases for data sharing and updated supervisory powers. The parliamentary process is under way: the government answered the committee report and submitted a first amending memorandum (both dated 17 June 2026) and a second amending memorandum (5 October 2026); the plenary debate in the House of Representatives is scheduled for 2 November 2026.
What does the FIU see in sanctions evasion?
On 6 October 2026 FIU-Netherlands reported 2,494 suspicious transactions with a sanctions component for 2025. Recurring patterns are U-turn structures via third countries, third-party payments, layering, trade in dual-use and luxury goods, and sham structures around oil and gas. These patterns belong as scenarios in the SIRA and transaction monitoring.
What does the new sanctions bill mean for institutions?
Prepare for administrative fines and remedial measures for inadequate sanctions compliance — where today enforcement runs almost entirely through criminal law and informal supervisory interventions. In practice: make sure governance, screening, reporting processes and record-keeping can withstand administrative-law scrutiny, and track how the central reporting point is implemented so that reporting flows (DNB, FIU, reporting point) do not start to overlap.