AFM’s June findings turn screening from a name search into a daily business discipline.
A small exporter can first feel sanctions compliance as delay. The order is ready, the invoice has gone out, the goods can move, and then the bank asks for more information. Who owns the buyer? Where is the end user? Why is the payment routed through that account? The commercial moment turns into a proof moment.
The signal has to become readable
On 18 June 2026, AFM reported findings from research by AFM and BFT into how audit firms with a regular licence handle sanctions risks around audit clients with Russian activities. AFM’s central point was plain enough. Awareness was broadly present. Control quality still needed work, especially in the reasoning behind the screening result.
That matters well beyond audit firms. Accountants, advisers, exporters, importers, technology suppliers, payment chains, and founders face the same question in different clothes. A sanctions check is no longer just a name search before acceptance. It is a business record that explains why a relationship, route, payment, service, or audit conclusion made sense at the time.
The signal behind the search
AFM said audit firms are an important link in compliance with Russia sanctions. It reviewed quality systems and business operations at six regular licence holders, involving about thirty statutory audits. AFM also said BFT reviewed Wwft client due diligence and monitoring at three regular licence holders in ten files.
There were good examples. AFM saw firms refuse clients with unacceptable risks, accept some clients only under conditions, consult the NBA or the Centrale Dienst voor In- en Uitvoer, use external screening, screen portfolios internally, and issue modified audit opinions in line with NBA Alert 45.
The improvement points matter more for daily business. AFM pointed to sanctions risk not always being built into policy, and risks sometimes being read too narrowly. It also named limited use of sanctions law experts, weak evidence around client-obtained legal advice, thin assessment of screening report scope and limits, and limited testing of management claims.
What the signal changes
The move is from awareness to ownership. A tool can produce a result. A person, a team, or a firm still has to own the reasoning.
Where the weak spot sits
A screening report has a dangerous neatness. It looks complete because it has a date, a name, a list, and an outcome. Sanctions risk often sits outside the exact name on the screen. It can sit in ownership, control, aliases, group links, a product route, a bank, a crypto channel, or an online payment platform.
Rijksoverheid reported on 23 April 2026 that the EU adopted a twentieth sanctions package against Russia. It covered additional shadow fleet ships, listed persons and companies, and anti-circumvention measures in countries including Turkey, the United Arab Emirates and China. It also touched banks, cryptocurrencies, and online payment platforms.
DNB and AFM’s sanctions alert of 10 June 2026 carries the same practical warning for supervised institutions. Firms have to check whether measures apply to clients, counterparties, transactions, products, or services. For a sensitive business file, the lesson is simple. When the world changes, the record has to move with it.
The UBO point belongs here. KVK says businesses and organisations provide UBO information themselves and must report changes within one week. KVK checks whether the information is there, but it does not decide who the UBOs are. A register extract helps. A sensitive case still needs a reasoned ownership reading.
Small firms meet sanctions through delay
The exporter from the opening scene may have no legal department. He may have a bookkeeper, a freight forwarder, a bank contact, and a customer who wants the goods quickly. That is exactly why the process has to stay proportionate and clear. Small firms do not need to copy bank bureaucracy. They need a file that holds the business logic.
CBS adds useful reality. On 5 June 2026, it reported that companies in the Netherlands with Russian majority ownership fell from 80 in 2014 to 25 in 2024. Employment at those companies fell from 1,276 to 176. Direct visible ownership has shrunk.
Another CBS signal shows why the issue remains live. In December 2024, CBS reported that Dutch exports of sanctioned goods to Russia were about 86 percent lower in 2023 than in 2018 to 2021. Exports of sanctioned goods to seven countries with elevated circumvention risk increased. CBS also noted many young, small firms entering those export flows.
What founders should check
For a founder, the risk may arrive as a new market, a new distributor, a changed delivery route, or a customer that looks ordinary until someone asks about the end use. The first cost is often time. Payments pause, shipments wait, buyers ask for proof, advisers need more documents, and management attention shifts from sales to explanation.
What a clear file looks like
A Rotterdam interim relief judgment, ECLI:NL:RBROT:2026:5294, published on 27 May 2026 and decided on 22 April 2026, shows another side of the same reality. The case between Lukoil Netherlands B.V. and Cargill N.V. concerned whether UK and US sanctions against the group to which Lukoil Netherlands belonged prevented performance of delivery obligations, and whether sanctions exemptions applied to the transactions.
That kind of file answers ordinary questions in ordinary language. Who was checked? Which ownership chain was reviewed? What did the screening cover? Were false positives resolved? What did management claim, and how was that tested? If legal advice was used, what facts were given and what transaction did the answer cover? Who watches new sanctions changes?
For audit firms, AFM’s fraud-risk finding deserves attention. In the audits it examined, none of the opinions included a fraud paragraph aimed at sanctions violation or circumvention. AFM said that risk would not be strange for audit clients with significant activities in Russia.
For smaller businesses, the same idea can stay modest. One named person can own the process. Higher-risk relationships can be refreshed when sanctions change. Ownership reasoning can sit with the customer or supplier file. Legal advice can stay tied to the facts submitted. Staff can pause when a route, payment, product, or counterparty stops fitting the story.
This is not about making every sale heavy. It is about preventing a thin check from pretending to be a strong decision. The calm files are often the ones where the hard thinking has already been done.
When the bank calls, a clear trail of judgment beats a folder of loose screenshots. The owner of a small firm should be able to say: this is who we dealt with, this is what we checked, this is why we accepted it, and this is what changed when the rules changed. That is where sanctions screening becomes real control.
Sources
- CBS source
- Onderzoek AFM en BFT: bewustzijn accountants rondom sanctierisico's is goed, beheersing kan beter
- AFM – AFM findings on sanctions risk control in audit firms
- AFM – Earlier AFM signal on clients with Russian ties
- Rijksoverheid – Latest Russia sanctions context and third-country evasion
- DNB – Current DNB and AFM sanctions alert
- AFM – Wwft, client due diligence, UBO verification and reporting threshold
- DNB – Sanctions screening control principle
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