On May 1, 2025, NLD DNB updated on reporting duties re deposits of RUS, BLR people.
Updated on various reporting obligations for deposits in context of sanctions against Russia and Belarus; banks expected to take action on a number of points by May 23.
For previous notifications in 2022, 2023 and 2024, NLD DNB acted as reporting point on behalf of competent authority i.e. Ministry of Finance, same procedure applies now.
NLD DNB will again act as reporting point and will not monitor compliance any further.
Banks must report deposits mentioned in the sanctions regulation to NLD DNB and must provide information by May 23, 2025, at the latest.
When reporting must use formats drawn up by EBA on behalf of EC (available online), same formats as for previous notification from 2024, which are also found in MyDNB.
Entities can provide requested information via MyDNB; if no deposits to report, must still fill in usual identification (1-Metadata), other template (2-Deposits) left empty.
This is to ensure all institutions see request and assess if reports need to be made.
New sanctions include crypto-assets of sanctioned (legal) persons, which must be frozen and that it is prohibited to make crypto-assets available to these persons.
For all sectors, NLD DNB is examining potentially further intensifying its supervision.
This may lead to a thematic investigation or a deep dive at individual institutions.
Expects entities check whether the Sanctions Act applies to them, their customers, participants or investments and if this is the case, immediately apply regulations.
If an institution identifies a legal person/entity referred to in sanctions (a 'hit'), they must report this immediately to NLD DNB, and answer any questions without delay.
A 'hit' could also be an unusual transaction within the Money Laundering and Terrorist Financing (Prevention) Act (Wwft), and should be reported to NLD FIU.
Institutions must comply with sanctions legislation in a timely and accurate manner.
Entities can also register to receive the NLD DNB sanctions regulations alert service.
Mar. 17, 2022 Update
On Mar. 17, 2022, NLD DNB reminded supervised institutions that all sanction hits must be reported not just the freeze transactions/sanctions and included examples.
Also outlined the EU sanctions package of Mar. 15, 2022 in more detail, see #131888.
If a sanctioned Russian bank tries to transfer money from a Dutch account at a bank or payment institution; if a director of a payment institution has been sanctioned;
If an insurer finds a customer has been sanctioned and no money can be paid out.
If a pensioner banks with a Russian sanctioned bank; when a trust service may not be provided to a sanctioned party; if a counterparty to a crypto transaction is sanctioned.
All sanction reports specifically relating to situation in Ukraine/Russia should be submitted to NLD DNB with retroactive effect from Feb. 23, 2022, by Mar. 21, 2022.
Mar. 30, 2022 Compliance Review
On Mar. 30, 2022, NLD DNB launched investigation into compliance with sanctions to determine if institutions are implementing adequate measures regarding regulations.
NLD DNB identified which supervised financial institutions may need to take measures in response to new sanctions packages; many institutions already received questions.
Enforcement measures may be taken if operations insufficient to adequately comply.
If an institution does not comply with sanctions, for example by not freezing assets when they should be, then it is a criminal offence (Economic Offences Act); if NLD DNB believes that this is the case, it will report this to the public prosecution service.
Apr. 12, 2022 Trust Services
On Apr. 12, 2022, NLD DNB issued updated guidance on sanctions against Russia.
Follows EU CNCL adopted fifth round of sanctions against Russia and imposed restrictive measures on an additional 217 individuals and 18 entities, see #134334.
Developments surrounding situation in Ukraine are currently following each other in rapid succession, expect institutions to ensure that they are kept informed about this.
Highlighted prohibition to register, provide registered office, business or administrative address as well as management services to, a trust or any similar legal arrangement.
Where trustor or beneficiary are Russian nationals/natural persons residing in Russia; legal persons, entities or bodies established in Russia; and certain other persons.
This concerns Anglo-Saxon legal form, not a trust office for which DNB issues a license.
Also bars to act or cause any other person to act as trustee or beneficiary if beneficiary is a Russian citizen, or is a natural person domiciled in the Russian Federation or if a legal person is or entity established in the Russian Federation, and for related parties.
Jun. 2022 Further Sanctions Update
On Jun. 7, 2022, NLD DNB updated on key aspects of EU's sixth sanctions package.
Ban on purchase, import, transfer of crude oil, certain petroleum products from Russia to the EU: gradual process over 6 months for crude oil, 8 months for other products.
Ban on specialized financial messaging services (Swift) to include: Sberbank (Russia's largest bank), SMEs (Moscow credit bank), Rosselkhoz bank (Russian Agricultural Bank), and Belinvestbank (Belarusian Bank for Development and Reconstruction).
Oct. 7, 2022 Sanctions Update
On Oct. 7, 2022, NLD DNB outlined expectations for supervised entities and advised that the EU imposed new sanctions against Russia on Oct. 6 , 2022, see #149166.
Wallet, account, crypto asset custody services for Russian nationals, natural persons in Russia, legal persons, entities established there now banned: previously €10,000 limit.
Supervised institutions are expected to keep up to date with latest developments, check whether any Sanctions Actobligations apply to them and act immediately if so.
Sanction hits must be reported immediately to DNB via digital supervision desk (DLT).
Advised of alerts emails on UN, EU, NL sanctions changes, with link to latest update.
Nov. 25, 2022 Clarification
On Nov. 25, 2022, NLD DNB issued clarification on sanction reporting obligation scope.
Has received multiple sanctions notifications since end of Feb. 2022, and is conducting investigations into compliance with sanctions regulations and reporting obligations.
On reporting under section 3 regulation on supervision of sanctions act 1977 (RtSw), institutions should only notify NLD DNB when sanctioned relationship is first identified.
Subsequent transactions with the sanctioned business partner do not need reporting.
Sanctions Act 1977 and RtSw updates are in progress, which may impact obligations.
May 17, 2023 Reporting in My DNB
On May 17, 2023, NLD DNB issued reminder that credit institutions must report the 'Reporting requirements under deposit sanctions' for Russia and for Wit-Russia.
From May 23, 2023, the reporting obligations will be visible in 'My DNB'.
This information requires credit institutions to provide pursuant to art. 5g(1)(a) and art. 5g(1)(b) of the Russia Economic Sanction Regulation (RSR), art. 5g(1)(aa) and art. 1z(a) and art. 1z(b) of the Belarus Sanction Regulation (BSR).
The obligation for both RSR and BSR must be submitted by May 29, 2023.
Reporting obligation for deposit balances of Russia nationals available under reference period Dec. 17, 2022 and Feb. 26, 2023; Mar. 10, 2023 for Belarusian nationals.
May 2023 Compliance Review Findings
On May 31, 2023, NLD DNB reported on findings from its investigations into financial institutions' compliance with sanctions regulations: solid but room for improvement.
New implementation questions arisen as a result of the new major sanctions packages; also cases where there is a real lack of action - DNB will take measures in such cases.
Shared generic observations and findings from the studies so that all institutions within the sectors studied can take note of them; institutions that were part of the above-mentioned studies have received individual feedback, or will receive them soon.
Jul. 2023 Reporting Obligations
On Jul. 4, 2023, NLD DNB issued an update re reporting obligations for deposits in the context of the sanctions against Russia and Belarus; banks must report the deposits mentioned in the Sanctions Regulation to DNB and provide the information by Jul. 18.
May 2025 Update
On May 1, 2025, NLD DNB updated on reporting duties re deposits of RUS, BLR people.
Updated on various reporting obligations for deposits in context of sanctions against Russia and Belarus; banks expected to take action on a number of points by May 23.
For previous notifications in 2022, 2023 and 2024, NLD DNB acted as reporting point on behalf of competent authority i.e. Ministry of Finance, same procedure applies now.
NLD DNB will again act as reporting point and will not monitor compliance any further.
Banks must report deposits mentioned in the sanctions regulation to NLD DNB and must provide information by May 23, 2025, at the latest.
When reporting must use formats drawn up by EBA on behalf of EC (available online), same formats as for previous notification from 2024, which are also found in MyDNB.
Entities can provide requested information via MyDNB; if no deposits to report, must still fill in usual identification (1-Metadata), other template (2-Deposits) left empty.
This is to ensure all institutions see request and assess if reports need to be made.
