Sanctions Watch | Weekly Vol. 96

Sanctions Watch Vol 96

In the latest edition of our Sanctions Watch weekly digest, we present significant updates on sanction watchlists and regulatory developments.

1. The Netherlands Amends Export Licenses to Exclude Israel from Dual-Use and Military Transfers

The Dutch government announced significant amendments to its general licenses governing the export and transit of dual-use and military items. Effective April 8, 2025, the National General Export Authorization NL002 which previously allowed eligible dual-use exports to most global destinations—has been repealed entirely. Additionally, NL010, pertaining to encryption-related dual-use exports, and NL007, concerning the transit of military items, have both been revised to exclude Israel as an eligible destination.

These regulatory changes signal a policy shift aimed at enabling greater scrutiny of sensitive transfers, especially in the context of ongoing geopolitical developments. While the affected transfers are no longer covered under the existing general licenses, exporters are not barred from conducting them entirely. Instead, they must now apply for transaction-specific licenses, which may still be approved on a case-by-case basis, following appropriate review.

Entities involved in relevant transactions are advised to assess whether alternative general licenses apply or prepare to initiate application processes for specific licenses. The Dutch government clarified that transfers previously conducted lawfully under these licenses remain valid, and standard record-keeping obligations continue to apply.

These changes reflect the Netherlands’ evolving stance on defense and security in response to international concerns.

2. UK Enforces Director Disqualification Sanctions to Strengthen Foreign Policy Measures

The UK government has introduced director disqualification sanctions under the Sanctions and Anti-Money Laundering Act 2018, utilizing Section 3A to deter and disrupt threats aligned with its foreign policy objectives. These sanctions make it a criminal offence for designated individuals to act in certain corporate roles within or connected to the UK without a valid license or applicable exception.

Under the effect of these sanctions, impacted individuals are prohibited from serving as directors of UK companies or foreign companies with sufficient UK connections—such as business operations or asset holdings within the UK. Additionally, they are barred from involvement in company promotion, formation, or management.

This prohibition applies uniformly across England, Wales, Scotland, and Northern Ireland, grounded in Section 11A of the Company Directors Disqualification Act 1986, and Article 15A of the Company Directors Disqualification (Northern Ireland) Order 2002. Violating these conditions constitutes a criminal offence, carrying serious legal consequences. Individuals subject to such sanctions are publicly listed on the UK Sanctions List, with details on the specific restrictions they face. The move underscores the UK’s commitment to using legal sanctions to combat corruption, illicit finance, and threats to national security.

3. Japan Extends Sanctions on North Korea for Two More Years Over Nuclear Threats and Abductions

The Japanese government announced a two-year extension of its independent sanctions against North Korea, originally set to expire on the upcoming Sunday. The decision was confirmed by Chief Cabinet Secretary Yoshimasa Hayashi during a press briefing at the Prime Minister’s Office. The extension is driven by serious national and international security concerns, specifically Pyongyang’s ongoing nuclear weapons and ballistic missile programs, as well as the unresolved issue of North Korea’s abduction of Japanese citizens.

Japan’s sanctions prohibit port entry of North Korean-registered vessels and any ships that have previously docked in North Korea. They also ban all exports and imports between the two nations. The Japanese government emphasized the importance of continuing these restrictions to reinforce the implementation of relevant U.N. Security Council resolutions aimed at curbing North Korea’s nuclear ambitions.

Hayashi noted that the decision was made following a comprehensive review of North Korea’s continued provocations and Japan’s commitment to maintaining regional stability and upholding international sanctions frameworks. These measures reflect Japan’s firm stance against North Korea’s defiance of international norms and underscore its ongoing efforts to protect national security and support the return of abducted nationals.

4. Nine European Nations Align with EU to Extend Sanctions on Russia

Nine European countries Ukraine, North Macedonia, Montenegro, Albania, Moldova, Bosnia and Herzegovina, Iceland, Liechtenstein, and Norway joined the EU’s decision to extend sanctions against Russia for an additional six months, until 15 September 2024. This unified action reaffirms their commitment to uphold Ukraine’s sovereignty and territorial integrity, following the EU Council’s move on 12 March 2024. The sanctions target over 2,100 individuals and entities, imposing travel bans, asset freezes, and a prohibition on providing funds to those deemed responsible for undermining Ukraine’s territorial integrity.

The Council also decided not to renew sanctions on three individuals and removed nine deceased persons from the sanctions list. The coordinated decision strengthens international pressure on Russia in response to its continued aggression, a policy first enacted by the EU in 2014 and consistently renewed since. Josep Borrell, the EU’s High Representative, acknowledged and welcomed the alignment by these non-EU nations, emphasizing their dedication to preserving European stability and international law. This development underscores a broadening consensus among European and partner states in confronting Russian hostilities and reinforcing shared foreign policy objectives within the framework of extended restrictive measures.

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Sanctions Watch is a weekly recap of events and news related to sanctions around the world.