Sanctions & Export Controls

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We align corporate goals with legal compliance

We assist our clients with their matters in the field of international trade, economic sanctions and export control regulations, helping them to navigate the complex patchwork of these regulations which are known for rapid change, overlap, broad scope and strict enforcement. We advise on the permissibility of transactions and the applicability of license requirements and other restrictions. If so desired, we assist clients in obtaining the necessary clearance from authorities, ranging from classification decisions to export licenses.

We also regularly conduct internal investigations into economic sanctions and export control related matters. We have ample experience in representing clients in economic sanctions and export controls related enforcement matters vis-à-vis various regulatory and criminal authorities. These include the:

  • U.S. Office of Foreign Assets Control (OFAC),
  • U.S. Bureau of Industry and Security (BIS),
  • Department of Justice (DoJ),
  • Dutch Ministry of Foreign Affairs; and
  • Dutch Central Department for Import and Export (CDIU).

We also advise a range of financial institutions on the specific requirements that apply to them in relation to economic sanctions and related governance issues, closely cooperating with our colleagues in our Financial Markets Regulation practice. Similarly, together with our M&A and Competition colleagues, we advise on transactions and foreign direct investment screening relating to strategic investments, notably those involving sensitive technologies.

As matters in this field often involve various jurisdictions, we keep close ties with specialised foreign counsel, including in the U.S. and the U.K., while the quickly evolving developments in China are covered by our own Shanghai office.

Our clients include multinational corporates and financials, based in the Netherlands and abroad. Clients value our advice for our multidisciplinary approach and ability to provide effective solutions, aligning corporate and commercial goals with legal compliance. In enforcement matters they choose us for our broad, multinational experience and ability to handle cross-border internal and regulatory investigations in close coordination with foreign counsel and authorities.


5 July 2023

China’s new counter-espionage law and recent enforcement raise data security compliance bar

On 1 July 2023, the newly revised Counter-Espionage Law came into effect in China. The amendments significantly expand the scope of activities that can be considered espionage by adding a catch-all provision, and codify the enforcement powers of relevant authorities. The revised law was first introduced in April 2023 amid a surge in Chinese enforcement activity against US-linked consultancy and due diligence firms, including a raid that was nationally broadcast in China.
6 June 2023

National security screening for investments – new Dutch regime up and running

Various geopolitical drivers have contributed to the proliferation of investment screening regimes that are based on national security concerns. Existing screening regimes have been expanded to include additional target activities. The EU has also been nudging member states to establish similar investment screening regimes or intensify the use of established ones. The vast majority of member states already have some form of foreign direct investment (FDI) control in place. The Netherlands, too, has adopted ministerial decrees necessary to implement its own investment screening system. This could affect the investment climate of the Netherlands, which has been historically known for its liberal disposition towards FDI. Investors contemplating acquisitions, or potential sellers, of designated vital providers or of companies active in sensitive technologies should anticipate uncertainty and a potential impact on transaction timelines due to an additional notification process.
17 March 2022

Russia takes measures against foreign intellectual property holders in response to sanctions

Russia has taken its first steps in seizing assets from Western companies that suspend operations in Russia because of imposed sanctions. Russia has retaliated by "suspending" their intellectual property, as they are parties affiliated with "unfriendly countries". The measure will have further implications for Western companies and their IP rights in Russia. A lower court ruling in Russia illustrates how Russia will probably allow the ongoing infringement of intellectual property rights.


Tency Zhou

Senior Associate