What are financial sanctions?

Financial sanctions are restrictive measures that are taken in respect of countries, individuals or entities with the aim of putting an end to breaches of international peace and security such as terrorism, human rights violations, the destabilisation of sovereign states and the proliferation of weapons of mass destruction.

These financial sanctions generally form part of a more comprehensive sanctions regime that also contains other restrictive measures, such as embargos on exports or imports of certain products (e.g. weapons, oil and technologies) or restrictions in terms of travel and visas.

Financial sanctions include:

• freezing measures
• bans on investment, loans or insurance in certain sectors
• financing the import or export of specific goods…

What are freezing measures?

Freezing measures are the most common form of financial sanctions. They are aimed at the individuals and entities targeted by the sanctions regimes and are designed to prevent them from financing their pernicious activities.

In practice, freezing measures consist of two components:

1. On the one hand, the obligation to freeze the assets of the individuals or entities in question.
2. On the other, a ban on making assets available to these individuals or entities.

Most sanctions regimes contain a list of individuals and entities to which the freezing measures apply. Individuals or entities will be regularly added to these lists or removed from them. In order to retain an overview of all the individuals and entities targeted by sanctions regimes applicable in Belgium, the Treasury maintains a consolidated and up-to-date list of these individuals and entities:

• The consolidated list can be found  here (XLSX, 928.35 KB).
• The XML version of the up-to-date list is available  here (ZIP, 1.08 MB). (based on XSD v.1.1 (ZIP, 2.75 KB)).

Who imposes sanctions?

The sanctions regimes applicable in Belgium are imposed at different levels:

• Internationally, imposed by the UN Security Council
• European, imposed by the European Union
• Nationally, imposed by the Belgian government (known as the 'national terrorist list') and the National Security Council

A range of other countries also impose sanctions. Although these sanctions can have an impact on certain economic sectors in our country, they have no legal force in Belgium.

Who must comply with financial sanctions and what is expected of them?

Everyone in Belgium is required to comply with financial sanctions. Financial sanctions may involve both obligations and prohibitions.

The most important obligations are:

• Freezing the assets of the individuals or entities to whom the freezing measures apply;
• Providing all information on the implementation of the financial sanctions, such as information on the frozen assets or information on any identified violations.

The most important prohibitions are:

• Making funds available to the individuals or entities to whom the freezing measures apply;
• Taking any actions that contravene the (financial) sanctions imposed.

The law provides for sanctions for non-compliance with restrictive measures

What is the role of the Treasury (FPS Finance)?

The General Administration of the Treasury is authorised to carry out the administration and compliance inspection for financial sanctions. This means that the Treasury is responsible for, inter alia:

• Answering questions relating to financial sanctions;
• Investigating cases of homonymy;
• Granting permission to deviate from certain financial sanctions;
• Handling requests to release or make available frozen assets;
• Managing information on the implementation of financial sanctions in Belgium;
• Verifying compliance with the financial sanctions.

You can contact the Treasury, for example to share information or ask a question, via quesfinvragen.tf@minfin.fed.be.