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International financial sanctions (United Nations)

United Nations freezing measures must be immediately applied in Belgium

The United Nations Security Council has passed many resolutions imposing sanctions on governments, persons or entities. These UN sanctions are transposed into European law by the European Union, which make them immediately applicable in Belgium.

Within the framework of these sanctions, the UN Security Council regularly adds names to lists of persons and entities whose assets must be frozen. In order for this freezing measure to be efficient, the funds freezing must be immediately applied, failing which the persons and entities concerned would have the possibility to protect their funds.

In the past, after each registration of a person or an entity on a sanctions list of the UN, the Minister of Finance issued a ministerial decree which froze the assets of this person or entity in Belgium as from the date of the decision of the UN Security Council till the date of the adaptation of this decision into European law. You will find here an overview of these ministerial decrees.

Not only this approach required a lot of administrative management, but the Financial Action Task Force (FATF) considered it as still not efficient enough to observe the international obligation to apply immediately the freezing measures of the United Nations Security Council in Belgium.

Title VIII (Articles 235 to 240) of the law of May 2nd 2019 laying down various financial provisions solves this problem by repealing the system of ministerial decrees (Article 238) and by stipulating that the freezing measures passed by the United Nations Security Council should be implemented as from the date of their passing (Article 236).

Even if, in the past, ministerial decrees already imposed the obligation to immediately implement the UN assets freezing measures, this new regulation increases the legal security. It is therefore no longer necessary to wait for the publication of the ministerial decree in order to be sure at 100 % that this UN assets freezing measure should immediately be applied.

The law provides for sanctions for any infraction against the obligation to apply UN freezing measures immediately (Article 237).

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