The sanctions law must be complied with by all organizations in the Netherlands (and abroad). This is even more important for organizations that do business with foreign companies and individuals. You are expected not to do business with individuals, countries, or organizations that appear on a sanctions list. To comply with the sanctions law, you must document how you do so. You determine the frequency of checks yourself, taking into account the type of customers and the sector in which you operate. 

Every organization in the Netherlands must at least check its relationships against the sanctions lists of NL, the EU, and the UN. If your organization has a branch in another country in addition to the Netherlands, you must also comply with that country's sanctions lists. Most Dutch organizations must comply with the US, EU, UK, NL, and UN sanctions lists. 

If a contact is on a sanctions list, check which sanctions apply to this person or organization. In most cases, you are not allowed to do business with them. If you have doubts, please contact our partners: Customs Knowledge or Martijn Feldbrugge at BSCN.  

If you do business with a country, organization, or individual that is on a sanctions list, you are committing an offense. You risk heavy fines and imprisonment.

You can comply with the sanctions law in 3 steps:

1. Check whether the organization and the individuals behind it are on a sanctions list.
2. Check whether the country or final destination is on a sanctions list.
3. Check whether your products are not Dual Use.

The European Commission has indicated that dual-use goods are goods normally used for peaceful purposes, but can also be used for military purposes. To prevent misuse, dual-use goods are subject to strict export regulations. Within the EU, an export license is required for the export of these strategic goods and services outside the EU. If the risk of misuse is too great, the license application will be rejected. These provisions are laid down in EU legislation: the EU Dual-Use Regulation. 

A dual-use scan is a tool that helps companies determine whether their goods fall under dual-use regulations. Dual-use goods are goods that can be used for both civilian and military purposes and are therefore subject to special rules. It is important to know whether your goods fall under dual-use regulations because exporting these goods without a license is a criminal offense. 

The main requirements for complying with dual-use regulations are identifying dual-use goods, obtaining the appropriate licenses for exporting these goods, and adhering to the regulations for exporting them. 

In total, there are more than 16,000 HS codes. Over 1,000 HS, CN, and Tariff codes may be dual-use. Each code can be associated with multiple Dual Use codes. 

The EU has compiled a very extensive list of Dual Use goods. A Dual Use item can apply to multiple HS codes, and multiple Dual Use goods can apply to a single HS code. To easily search this list, you can enter 1 to 2,000 HS, CN, or Tariff codes at once in Sanctioncheck. It will then show whether there is a match or not.

A dual-use scan works on the basis of HS, CN, or Tariff codes, which are used to classify goods for customs purposes. The scan checks whether your goods' code appears on the list of dual-use goods, thus determining whether your goods fall under dual-use regulations.

Failing to comply with dual-use regulations can lead to heavy fines, seizure of goods, or even criminal prosecution. It is therefore important to carefully adhere to these regulations. 

Yes, it is possible to manually check whether an HS code falls under dual-use regulations. The very extensive list from the EU can be found here.