What is the Sanctions Act?
In the Netherlands, the implementation of (international) sanctions is regulated by the Sanctions Act. This Sanctions Act aims to combat, for example, illicit trafficking, money laundering and terrorism. In order to maintain international peace and security. The legislation prohibits doing business with persons and organisations on sanctions lists or from countries that are sanctioned.

With this law, the Netherlands implements international sanctions regulations from the United Nations, the European Union and the Netherlands, among others.

What are sanctions?
Sanctions are measures in the form of:

restrictions on financial transactions (lending, payments, etc.);
a ban on trading in a general sense;
a ban on trading in specific goods;
travel and visa restrictions.

What measures do we take for this?
When you apply for insurance with us, we check whether you, an insured or the beneficial owner (UBO) is on a sanctions list. If this is the case, we will have to reject your application.

If you already have insurance with us, we regularly check whether policyholders, insured persons and beneficiaries appear on one of the sanctions lists. Is this the case? Then we must terminate the insurance and report this to De Nederlandsche Bank.

This check also takes place in case of a claim payment. If there is a payment to or for the benefit of a sanctioned party, we are not allowed to pay out.

What does this mean for you?
For this, if you operate a business, we ask you to indicate who in your organisation is the ‘ultimate stakeholder’ (UBO). That is the person who is/are ultimately the owner(s) and/or beneficiary(ies) of the organisation. You declare this via the UBO form, which you will receive from us as part of the application process. This form further explains the term “UBO”.