Sanctions and export controls in 2026: where Dutch business is most exposed

For Dutch exporters, the trade-compliance landscape has shifted under foot. The Fiscal and Economic Investigation Service (FIOD) set up a dedicated sanctions enforcement team in 2025. Investigations and site visits are on the rise. The 20th EU sanctions package has landed, and the catch-all goods list has widened to a point where common consumer goods sit alongside the obvious dual-use items.

At the second ICC Netherlands Digital Business Lunch on 26 June, more than 40 trade and compliance professionals joined Floor Koops, partner at Bennink Dunin-Wasowicz, and Ruud Altena, corporate compliance leader most recently at Braskem, for a practical conversation on where the risks now sit and what business should do about them. The session was moderated by Andrea Cardoso.

A widening net

The most striking trend, Koops said, is the steady tightening of the EU sanctions framework. Recent measures include new contractual clauses to prevent tankers being resold to Russian buyers, port infrastructure bans (including in Indonesia), restrictions on Russian crypto-asset providers, and an EU activation of its anti-circumvention tool with a full ban on certain exports to Kyrgyzstan. The number of exemptions and derogation options is shrinking.

For an audience broadly familiar with sanctions, the most surprising element is how broadly the catch-all goods list now reaches. Typewriter ribbons, used clothes and seats for motor vehicles are now among the items restricted from export to Russia. A common reaction in the audience: we assumed our products were too ordinary to be caught.

On Iran, Koops flagged the recent EU framework allowing further restrictive measures in response to actions threatening the freedom of navigation in the Strait of Hormuz, on top of restrictions tied to UAV manufacture, technical assistance, brokering and intellectual property.

The under-prepared side

Companies focus heavily on the export side and miss the import restrictions, Koops said. Since January 2026, the EU has restricted the import of petroleum products bought from other countries when they contain Russian-origin oil. Cigars, pebbles, refrigerators and dishwashers are also caught.

Services are the other blind spot. EU restrictions cover two categories: outright bans on providing certain services to Russia (engineering, technical, IT and others), and services tied to goods that were previously restricted from export. Koops described seeing cases where a Dutch company owns goods already inside Russia from before 2022, and is now still prohibited from servicing them because of the underlying restriction. “If you do business in Russia or you have a subsidiary in Russia, there is almost no chance that you don’t also provide a service,” she said.

Is a ship just a ship?

Altena brought a case to the room. A USD 550 million shipbuilding project, financed in part by a Norwegian pension fund, sourced eight vessels from a Chinese shipyard. Due diligence revealed that the shipyard also built military vessels. The vessels were destined for Asia and South America, never the United States, but the team could not fully eliminate the risk that, somewhere in the operating life of the ship, US sanctions would touch the crew, the maintenance, the bunker fuel or the flag.

“Is a ship just a ship? It’s much more. It’s by itself a legal entity. It’s a floating village requiring a crew, requiring maintenance of the ship itself, of the equipment on board,” Altena said. Each layer carries its own sanctions exposure. Sanctioned parties can supply bunker fuel, provide maintenance, or sit in the crew roster. The flag adds a diplomatic angle.

Asked what he would do differently with the benefit of hindsight, Altena was direct: he would have pushed harder for South Korea over China. More expensive, politically safer, and the project sponsor would have slept better.

The spare-parts trap

Where Koops sees classification go wrong most often is in the treatment of spare parts. Companies routinely classify spare parts under the same HS code as the main good. The main good ships under its own export licence, but the spare part, taken on its own, may require a separate licence under the EU dual-use regime. A maintenance contract triggers a shipment of spare parts months later, customs treats it as classified, and the company has unwittingly breached.

Even within the EU, certain dual-use items require a licence. A common mistake is to assume that intra-EU shipments are out of scope. They are not.

Tone from the top

On compliance programmes, Koops and Altena converged on the same message: trade compliance can no longer sit only with legal or the compliance function. A workable programme starts with a thorough risk assessment covering sector, goods exported and imported, counterparties (direct and indirect), geographies and modes of transport. From that assessment, a company can design a tailored programme with concrete steps, clear escalation paths, and workflows tailored to sales, procurement and supply chain.

“Compliance should not be something that is a legal or compliance thing, but it should really be owned by the business,” Koops said. Sales, procurement and supply chain are the face of the company to the world. They have to own the risk. A clear, communicated risk appetite (what countries, what sectors will we not touch) is, in her view, the single most effective control a business can put in place.

Altena added the operational piece. A regular survey of middle management, scoring the compliance posture on tariff classification, valuation, customs management and other dimensions on a one-to-five scale, lets a company track which weak points are improving and which are not. Annual full reviews, quarterly check-ins on the weaknesses. Document everything, train staff, audit at intervals.

When the bank calls

A significant share of unintentional breaches surface through bank payment screening. Koops urged companies to cooperate fully and document their answers carefully. Reluctance to share creates a worse problem than disclosure does. Banks that do not get clear answers will not process transactions, and over time they will close the account. Reopening an account elsewhere is materially harder than most companies expect.

What Dutch businesses can start doing now

Asked to close with five practical priorities, both speakers landed on overlapping but complementary lists.

From Floor Koops: first, make sanctions and export-controls compliance a tone-from-the-top priority. It is a competitive advantage. Second, run a risk assessment and design a tailor-made compliance programme around it. Third, classify all of your goods, including spare parts. Fourth, set clear escalation paths, with business units owning the risk. Fifth, embed the culture: trade compliance as a strategic capability, not a backstop.

From Ruud Altena: first, keep classification up to date, and aim not just for “correct” but for “optimised” for your supply chain. Second, validate your export tools and have a real conversation with your customs broker. Third, go beyond tier-one screening into the supply chain, on both supplier and customer sides. Fourth, take services seriously. They can be sanctioned, and the sovereignty discussion is widening the scope. Fifth, leverage tariff and free-trade agreements. They are also opportunities, and the Finance Director will thank you.

The road ahead

Through its Business Integrity Commission, ICC Netherlands continues to develop practical guidance across five working groups. The first deliverable, a set of minimum standards and plain-language one-pagers on sanctions compliance, is expected to be published after the summer, with further work underway on anti-corruption, integrated due diligence, and boardroom ethics.

ICC Netherlands shares this work openly, and welcomes new organisations to join.

The Digital Business Lunch is a monthly online series discussing the issues that move international trade, covering a range of subjects from tariffs and customs reform to AI in trade compliance, sustainability and IFRS.

For more information about upcoming Digital Business Lunches: Events & Trainings | ICC WBO Netherlands or our LinkedIn page.