DNB and AFM Issue August 2026 Sanctions Update Covering ISIS, Al Qaeda, Russia, Ukraine, Belarus, an

Key Takeaways

• DNB and the AFM have published their monthly sanctions alert, detailing regulatory amendments and rectifications affecting sanctions regimes related to ISIS/Al Qaeda, Russia, Ukraine, Belarus, and Libya during August 2026.
• Dutch financial institutions must assess whether these changes impact their customer base, transactions, or investments and take immediate action if a sanctions hit is identified.

Deep Dive

This update serves as a periodic notification from DNB and the AFM summarizing changes to EU and national sanctions regimes during August 2026. While the notice itself does not introduce new sanctions frameworks, it flags multiple amendments and rectifications to existing regulations affecting five distinct sanctions programs: ISIS/Al Qaeda-related measures (amended August 21 and 27), Russia-Ukraine measures (amended August 7, with rectifications on August 6 and 11), Belarus-related measures (rectified August 11), and Libya-related measures (amended August 7). Each change corresponds to specific EU implementing regulations or decisions that institutions must review against their own screening systems and watchlists.

For compliance teams, the critical takeaway is the obligation to promptly determine whether these regulatory amendments affect existing customer relationships, counterparties, or investment holdings. Both regulators reiterate standard sanctions compliance obligations: immediately freezing applicable funds or economic resources, preventing indirect or direct provision of funds, and halting any prohibited financial services. Institutions identifying a "hit" against updated sanctions lists must report this without delay—DNB-supervised entities via Mijn DNB's Supervision Request service, and AFM-supervised entities via the designated email address and reporting form.

A notable compliance nuance is the overlapping reporting obligations: a sanctions hit may simultaneously trigger Wwft unusual transaction reporting to FIU-Netherlands and, separately, incident reporting requirements under the Bpr (for DNB-supervised institutions) or BGfo (for AFM-supervised institutions). Compliance teams should ensure their sanctions screening procedures are integrated with AML/CTF reporting workflows and incident management frameworks to avoid regulatory gaps. No explicit deadlines are given beyond "immediate" action upon identifying a hit, placing the onus on institutions to maintain continuous, real-time screening capabilities.

From a risk perspective, failure to promptly update screening lists or recognize a hit could expose institutions to regulatory enforcement, reputational damage, and potential facilitation of prohibited transactions. Given the breadth of jurisdictions and entities covered (terrorism-related, Russia/Ukraine conflict, Belarus, and Libya), firms with cross-border exposure or correspondent banking relationships face elevated risk. Recommended actions include immediately updating sanctions screening databases with the referenced implementing regulations, conducting retrospective reviews of recent transactions against the amended lists, and confirming internal escalation procedures align with both DNB and AFM reporting channels.

Source: De Nederlandsche Bank