Stéphanie Broekaart contributes to The Sanctions Compliance Manager’s Handbook

The international sanctions landscape is more complex than ever. The Sanctions Compliance Manager’s Handbook, edited by Tom Blass (WorldECR), is a practical reference work on sanctions legislation and sanctions compliance. We are proud that Stéphanie Broekaart of Agorax, a specialist in sanctions law and export control, has contributed to this handbook as an author. The […]

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Control in EU sanctions: when is there sufficient evidence to justify inclusion on a national sanctions list and the freezing of assets?

An EU Member State is obliged to freeze the assets of an undertaking where a sanctioned person or entity exercises control over that undertaking and may adopt national implementing measures to that end. The control in question must be substantiated by objective and sufficiently robust evidence. The form of government of a state, even if […]

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Turbo liquidation without notifying creditors: is the director liable?

If a company is wound up by means of a turbo liquidation (also known as fast-track liquidation) without the director fulfilling their duty to notify creditors, this may result in liability on the part of that director. This is evident from a judgment of The Hague District Court dated 8 July 2026 (ECLI:NL:RBDHA:2026:21059). What were […]

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Can an EU bank refuse a basic bank account because of an OFAC listing?

In Jenec (Case C-81/24), the Court of Justice of the European Union (CJEU) held that a bank must first carry out an individual assessment of the money-laundering and terrorist-financing risk associated with the proposed relationship. An OFAC listing may justify enhanced scrutiny. It is not an automatic ground for refusal. The judgment matters to banks, […]

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EU’s 21st Sanctions Package Against Russia

It is safe to say that, after more than four years of targeting Russia’s economy, the package introduces no groundbreaking new measures. The 21st package signals the EU’s willingness to maintain pressure, but it also seems that further reaching economical restrictions increasingly require concessions from individual Member States that those states have shown themselves unwilling […]

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Duty to disclose in business acquisitions: silence is no defence

Anyone who is aware of a problem and conceals it cannot, in the event of a breach of warranties, hide behind the buyer’s duty to investigate. This is clear from a recent judgment by the Amsterdam District Court (ECLI:NL:RBAMS:2026:4722). What were the facts of this case? In 2021 and 2022, an investor provided loans to […]

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