Sanction lists
Sanctions lists show which individuals, companies, and countries are prohibited or restricted from doing business with. They are an essential part of compliance, KYC, and CDD processes for organizations that must comply with laws and regulations.
What is a sanctions list?
A sanctions list is an official list of individuals, companies, organizations, and countries with which the prohibited or restricted is to engage in business or financial transactions. Sanctions lists are drawn up by governments and international bodies for political, economic, or security reasons. For organizations, these lists are a mandatory part of compliance, KYC, and CDD processes.
Failure to comply with sanctions lists may result in heavy fines, criminal penalties, and reputational damage.
What does a sanctions list mean for organizations?
Organizations are legally obliged to check whether they are doing business with sanctioned parties. This applies not only when entering into a new relationship, but also throughout the entire duration of the customer or supplier relationship.
Sanctions lists therefore play a central role within:
- Compliance and risk management
- Know Your Customer (KYC)
- Customer Due Diligence (CDD)
- Wwft obligations
What sanctions lists are there?
There are several sanctions lists that organizations must consult. These often need to be used in combination.
EU sanctions list
The EU sanctions list includes individuals, companies, and countries that have been sanctioned by the European Union. These sanctions may consist of:
Freezing of assets
Trade restrictions
Prohibited from providing services
The Russia sanctions list contains Russian individuals, companies, and entities subject to EU and national sanctions measures. This list has expanded significantly since the conflict in Ukraine and changes regularly.
National sanctions lists
In addition to international lists, countries also publish national sanctions lists. In the Netherlands, these are based on:
EU decisions
- UN resolutions
- The Dutch Sanctions Act
Organizations must always check which national obligations apply to them.
Sanctions list Netherlands: What do you need to know?
The sanctions list Netherlands is relevant for all organizations that fall under Dutch law.
Key points:
- Application: financial institutions, real estate agents, notaries, and other parties subject to the Wwft must use these lists.
- Source: The lists can be found on the government website or via (automatic) compliance software.
- EU and Russia: Dutch sanctions lists often contain EU decisions, including sanctions against Russian individuals or companies.
- Monitoring: organizations must periodically check whether existing customers appear on the list.
Practical example: For a new business relationship, check the name of the company and the UBOs against the Dutch sanctions list, the UN list, and the EU list to avoid serving a sanctioned party.
Sanctions lists within KYC and CDD processes
Sanctions lists are an integral part of every KYC and CDD process.
Screening during onboarding.
When entering into a new business relationship, organizations must:
- The organizations monitor
- Screening the UBOs (Ultimate Beneficial Owners)
- Checking against EU, UN, and national sanctions lists
Continuous automated monitoring
Sanctions screening remains necessary even after onboarding. New sanctions can suddenly cause an existing relationship to pose an increased risk.
Automated monitoring helps organizations to:
- Remaining continuously compliant
- Respond quickly to changes
- Preventing manual errors
Sanctions lists are part of Compliance Management. Read more about this on our Compliance page.
