Netherlands Floats Ideas for Boosting Sanctions Enforcement
The Netherlands recently released a "non-paper" covering ways to boost its sanctions enforcement. The proposals include elevating information sharing between EU member states, establishing an EU point of contact and platform for sanctions circumvention data, using diplomatic tools to increase sanctions compliance and fight circumvention, and expanding the EU's designation criteria to include individuals and entities in third-party countries involved in sanctions circumvention for the use of products on the battlefield in Ukraine.
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In addition, the Dutch government floated the idea of expanding the EU "toolbox" by issuing guidance on recognizing and fighting circumvention patterns; issuing official warnings to parties outside the EU; creating a watch list of companies, sectors and trade flows of note; encouraging contractual end-use obligations in key sectors; and using trade measures when a third-party country refuses to act on circumvention in its borders.