Dutch Court Upholds Sanctions Violation Penalties

The Netherlands' Rotterdam District Court on Jan. 15 sustained the Dutch National Bank's sanctions on an unnamed financial services provider, according to an unofficial translation. The court held that the bank "rightly" found that from July 2015 to March 2018, the financial services provider "systematically failed to comply with several core obligations" by "hardly conducting any customer due diligence" and failing to carry out any sanctions screening.

The court dropped the fines to approximately $782,000 and $491,000 for the various offenses after holding that there is "no reason to assume an increased severity of the violations with regard to the administrative fines" for the sanctions violations. While there is little guidance on distinguishing between ordinary and serious violations of this type, "the court considers that the gatekeeper role" of the Dutch National Bank is "too heavy."