Sanctions may be imposed by both administrative and criminal authorities. Regulators, enforcers and investigative agencies exist in a variety of forms and manifestations. In addition to the police, a large number of other government agencies may also be involved in enforcing and ultimately imposing sanctions, such as, for example, the Autoriteit Financiële Markten (AFM) (the Dutch Authority for the Financial Markets), the Autoriteit Consument & Markt (ACM) (the Netherlands Authority for Consumers & Markets), Environment Agencies, Inspectie Sociale Zaken en Werkgelegenheid (ISZW, the former Labour Inspectorate) (Inspectorate SZW), the Tax Authorities, the Fiscale Opsporings- en Inlichtingendienst (FIOD) (the Fiscal Intelligence and Investigation Service ), the Nederlandse Voedsel- en Warenautoriteit (NVWA) (the Netherlands Food and Consumer Product Safety Authority) and the Inspectie Leefomgeving en Transport (ILenT) (the Human Environment and Transport Inspectorate). The officials employed with the aforementioned hybrid agencies often have special investigative powers and may act both as regulators and as enforcers (both under administrative law and under criminal law). To an undertaking and those involved with it is not always clear on the basis of which powers they are held to account and what exactly their rights and obligations are in such a case.
Legaltree has the expertise to assist you in matters involving administrative law and criminal law sanctions. Multiple expertise is of particular importance where incidents (such as accidents at work or pollution incidents) and searches (by the Fiscal Intelligence and Investigation Service, the Dutch Authority for the Financial Markets, the Netherlands Authority for Consumers & Markets and/or the police) are concerned, in which situations it is recommended to set up a team comprising all the relevant specialisms.
The following specialized practice areas may be of importance in the case of sanctions:
- Corporate criminal law
- Environmental law
- Government and Business
- Regulated markets
- Competition law
The following partners are specialized in Sanctions Law: