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ARTICLE · 30 JANUARY 2026

Dutch Enforcement Puts ESG Claims And Sanctions Compliance Under The Microscope

A&O Shearman
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In 2025, Dutch enforcement authorities prioritized targeted indictments and penalty orders, with new guidance on self-reporting and cooperation shaping internal investigations.

NetherlandsCriminal Law
Patrick Ploeger
Patrick Ploeger
Jasper Strijder
Jasper Strijder
Iris van den Oord
Iris van den Oord
Kyomi Bottse
Kyomi Bottse
Maxime Aarts
Maxime Aarts
Mohamed Zaatout
Mohamed Zaatout
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In 2025, Dutch enforcement authorities prioritized targeted indictments and penalty orders, with new guidance on self-reporting and cooperation shaping internal investigations.

No major law reforms occurred, but notable developments included enhanced privilege protection and expanded powers for the Financial Intelligence Unit. The transportation and financial sectors were key enforcement targets, while consumer protection and environmental crime also saw increased focus.

Cross-border enforcement intensified, highlighted by the first EPPO-led conviction and ongoing sanctions coordination. Looking ahead, ESG obligations, sanctions compliance, anti-money laundering, and anti-corruption measures will continue to be areas of interest for in-house legal teams. Internal investigations must balance transparency, data governance, and whistleblower protection, as technology and regulatory scrutiny continue to evolve.

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