Sanctions & AML
Covers international sanctions screening, AML due diligence — the first security gate when Jiumo matches overseas clients under 「Supply Chain Landing」.
1. EU sanctions regulations are directly effective in all Member States (including the Netherlands). No entity may transact with sanctioned individuals or entities.——EU Treaty Art.29 + TFEU Art.215 EU Consolidated Sanctions List, regularly updated
2. The Dutch Sanctions Act criminalises sanctions violations; violators may face criminal prosecution and substantial fines.——Dutch Sanctions Act 1977 Modernisation bill in progress
3. Service providers must complete customer identification and verification (KYC due diligence) before establishing a business relationship.——Dutch AML Act (Wwft) Art.3 Effective 2008, regularly amended
4. Suspicious transactions potentially involving money laundering or terrorist financing must be reported to the Financial Intelligence Unit (FIU).——Dutch AML Act (Wwft) Art.4
5. Service providers must screen customers against sanctions lists.——Dutch AML Act (Wwft) Art.5
6. Service providers must identify and record the UBO of clients and register in the Dutch UBO register as required.——Wwft Art.10 + Implementing Decree Dutch UBO Act 2020
7. Business with any US nexus (including USD settlement) requires screening against the US Treasury OFAC SDN List.——IEEPA; 31 CFR Part 500 et seq. OFAC Sanctions Programs
8. UN Security Council sanctions resolutions are binding on all Member States and must be implemented at the national level.——UN Charter Chapter VII UNSC Resolutions
9. Re-export, transit, and transhipment of controlled items are subject to export controls; confirm whether a new licence is required.——Export Control Law Art.44-45 EAR Part 734
10. Sanctions violations may lead to: fines, criminal liability, frozen bank accounts, reputational damage, and platform delisting, among other consequences.——Sanctiewet 1977, penalties Wwft, penalties
11. Service providers must conduct regular compliance training for relevant staff and retain transaction records for at least 5 years.——Wwft Art.33 EU 4AMLD/5AMLD/6AMLD
12.Suspected sanctions matches must trigger immediate transaction hold and reporting to the compliance officer for internal verification.——Internal Compliance Manual Wwft Art.16