Dealt with a sanctioned party — what to do now

1. Stop paying, shipping and delivering. Continuing to deal with a listed party is a separate violation for every transaction after you knew. If goods are in transit, your lawyer decides next steps — not your forwarder.
2. Freeze, don't return. If the listing is an asset freeze (the EU 269/2014-type), funds you hold for them may not be made available — and that includes sending their money back. Unfreezing needs permission from your national authority.
3. Check it is the same party. A name hit is a lead, not an identification. Same name, different country, different registration number? Ownership above 50% by a listed party counts too — even when the subsidiary itself is not listed. Our free check shows the ground for every hit: read it before you act on it.
4. Write down what you knew and when. A dated file of what you screened, when, with what result, is the difference between an inadvertent breach and an intentional one — and that difference is the whole penalty range below. A €29 dated record is the cheapest piece of that file.
5. Get a sanctions lawyer before self-reporting. Report nothing to customers, banks or authorities before advice. In the Netherlands a lawyer's advice is privileged; your own e-mail trail is not.

• Netherlands: violations of the Sanctiewet 1977 are economic crimes (misdrijven when intentional), enforced by the FIOD, with a six-year maximum and fifth-category fines. A 2024 Rotterdam judgment convicted on Regulation 833/2014 breaches — this is not theoretical.
• EU-wide since Directive (EU) 2024/1226 (transposition due 20 May 2025): intentional violations must carry imprisonment — at least 1, 3 or 5 years' maximum depending on the offence, with circumvention at the top; legal persons face fines of at least 1% or 5% of worldwide annual turnover, or €8–40 million.
• No intent for the core prohibition: making funds available to a frozen party violates the regulation whether or not you knew. Intent sets the criminal ceiling; the absence of documented screening sets your exposure.
• Enforcement is real: roughly €550 million in fines and some 1,400 convictions or penalties across 32 European countries since 2017, and rising.
• US dollars anywhere in the chain add OFAC exposure: civil penalties per violation can exceed the transaction value several times.

What protects you is the same thing that prevents this page from applying to you: documented screening before payment, repeated when lists change.

• Why your bank flags parties the EU has not listed: EU banks screen the UK, US and other lists too. A counterparty listed in London and not in Brussels still stops your payment — see why the UK list matters to an EU business.
• What the bank does: stop the transaction, file a report to the Dutch central bank (DNB) where required, and ask you to explain the counterparty. Onboarding can stall for weeks — that costs more in practice than the stopped invoice.
• What works: send the bank your dated screening records, the counterparty's registration data, and the invoice chain. The bank's financial-crime team is looking for a reason to release; give them one that is documented.
• What does not work: moving the payment through another bank or another country. That converts a screening question into a circumvention investigation, and circumvention carries the heaviest penalties of all.

The EU's own helpdesk puts it plainly: documented due diligence protects you in the event of inadvertent breaches. What that means in practice:

• Screening records dated before payment are evidence of good faith — a screenshot of a search box proves nothing, because nobody can tell what the list contained that day.
• Re-screening matters: a party screened clean in January says nothing about a shipment in April. Lists change with every round — which is what daily monitoring is for.
• The 50% rule catches the unscreened: a company that is more than half owned by a listed party is covered even though its own name appears nowhere. "They weren't on the list" is not a defence when the owner was.

• Why lawyer first: what you write in a disclosure can be quoted in a prosecution. Privileged advice maps the exposure before anything leaves the building.
• OFAC route: voluntary self-disclosure through OFAC's disclosure process is the single largest mitigating factor in US civil enforcement.
• EU route: your national competent authority (in the Netherlands, via your lawyer) accepts cooperation and remediation as mitigating factors; the 2024 directive requires member states to allow them in sentencing.
• What remediation looks like: stop, freeze, screen the whole counterparty portfolio, fix the gap, and document all of it. That is a mitigation story a prosecutor recognises.

• Exceptions exist and are real: the Russia regulation has legal-fee, living-expenses and prior-obligation carve-outs under strict conditions; the national authority grants them case by case.
• Goods in transit: a listed buyer does not automatically void title, but delivering may be prohibited — get advice before the container moves.
• Your own receivable from a frozen party is stuck with them: netting it against what you owe them is exactly the "making available" the regulation prohibits.

• Ploum (Rotterdam) — publishes on the Dutch Sanctions Act and its replacement; trade and sanctions practice.
• Houthoff — corporate crime and EU sanctions team; enforcement defence.
• Law & More — publishes on the criminal consequences of Russian sanctions violations.
• What to bring: your dated screening records, the contracts and payments, and a one-page timeline. The €29 dated screening record is the document every lawyer asks for first — get it before the call.

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