On 12 August 2020, the Dutch Ministry of Finance published a Guideline on Financial Sanctions Legislation (the Guideline). The Guideline serves as a general explanation about the effect of financial sanctions measures in the Netherlands and aims to clarify the implementation of the sanction measures for the parties involved.

The Guideline consists of a general part containing an introduction to the financial sanctions measures that apply in the Netherlands, followed by a list of frequently asked questions. The questions are inspired by, among other things, issues that public and private parties have shared with the Dutch Ministry of Finance.

The Dutch Minister of Finance is also the competent authority for assessing exemption and permit requests in relation to financial sanctions. The specific sanctioning instruments (EU regulations or national regulations) indicate under which conditions (for example for basic necessities, legal assistance or humanitarian grounds) the Dutch Minister of Finance as the competent authority may grant an exemption. Each case is tested against these conditions; the Guideline explains this process.