Overview
Belgium is a UN and EU member state and implements UN and EU sanctions. EU sanctions are directly applicable in Belgium. Their implementation and enforcement in Belgium is governed by the Law of 13 May 2003.
UN Security Council sanctions are implemented by the EU into European law, making them immediately applicable in Belgium. UN sanctions apply in Belgium from the moment they are passed by the UNSC, under Article 236 of the Law of 2 May 2019.
Belgium has an autonomous sanctions regime against terrorist financing governed by the Royal Decree of 28 December 2006, as modified by the Royal Decree of 29 March 2024.
National Competent Authorities
The General Administration of the Treasury is the competent Belgian authority for sanctions and has the power to investigate and record sanctions offences.
The Public Prosecutor’s Office is responsible for prosecuting sanctions violations.
The Belgian Financial Intelligence Unit (CTIF-CFI) deals with suspicious financial transactions.
The General Administration of Customs and Excise Duties enforces trade sanctions.
The National Security Council is responsible for establishing and amending the national list of sanctioned persons in Belgium. This consolidates UN, EU, and autonomous sanctions.
Export controls on weapons, military and paramilitary equipment and dual-use goods are managed by the Directorate General for Economic Potential. There are regional authorities for export controls for Brussels, Wallonia, and Flanders. Export controls on other goods and services, including financial services, are managed by the Directorate General of Economic Analysis and International Economics. Export controls on the energy, nuclear, and shipping sectors are managed by separate authorities.
Legislation
Law of 11 May 1995 regarding the implementation of UNSC decisions.
Sanctions Lists
Belgium maintains a consolidated list of people and entities subject to Belgian, EU, and UN Sanctions.
Belgium also maintains a national sanctions list of individuals and entities sanctioned under the Royal Decree of 2006.
Guidance
Financial sanctions and money laundering
CTIF Reporting guidelines (French only)
Licensing
Requests for licences / derogations from sanctions should be addressed to the General Administration of the Treasury by emailing quesfinvragen.tf@minfin.fed.be
The application must include the following information:
- The relevant sanctions regulation and article.
- The identity of the debtor/instructing party.
- The identity of the creditor/beneficiary.
- The amount and the currency unit of the transaction.
- The reason for the request.
- Relevant data on the banks and organisations involved in the transaction.
- The date of the agreement or obligation for which payment is due
- Supporting documents for verification (e.g. invoices)
- If the application is for the transfer of goods, a description of the goods and an information sheet.
- If the application is for the transfer of weaponry or dual-use items, an authorisation from the relevant regional export control authority.
Organisations can apply to the treasury to verify whether a designated individual is the correct person in cases of homonymy by emailing quesfinvragen.tf@minfin.fed.be.
Enforcement
Violating EU sanctions carries a penalty of up to 5 years imprisonment and a fine of up to EUR 25,000 under Article 6 of the Law of 13 May 2003. Entities may also be subject to an administrative fine of up to EUR 2.5 million.
The same penalties apply for violations of UNSC sanctions under Article 4 of the Law of 11 May 1995 and Article 237 of the Law of 2 May 2019.
Belgium received a letter of formal notice from the EU Commission for failing to transpose the EU sanctions enforcement harmonising directive. In order to implement the Directive fully, Belgium will have to implement increased administrative penalties.
Reporting
EU reporting requirements apply in Belgium. These obligations are set out in Council regulations and require natural and legal persons, entities and bodies to supply “any information which would facilitate the implementation [of sanctions]… to the competent authority of the Member State where they are resident or located.” See our EU Reporting page for more details.
Information on the implementation of sanctions and asset freezes should be reported to the Treasury:
Minister of Finance, c/o General Administration of the Treasury,
Avenue des Arts, 30
1040 Brussels
Email: quesfinvragen.tf@minfin.fed.be
Financial institutions must report suspicious transactions to the CTIF using goAML.
Guidance is available on the website of the National Bank of Belgium (NBB) and in a separate report by the CTIF.
There are specific reporting requirements for importing, exporting and transferring liquified natural gas.
Export controls
EU export controls apply in Belgium.
The competent authority for granting export licences for military and dual-use goods depends on the location of the exporter requesting them:
Brussels
Brussels publishes guidance and FAQs on dual-use goods exports. It also has an online questionnaire to assist exporters in finding the correct permit class and a full list of relevant forms.
Brussels Regional Public Service,
Place Saint-Lazare 2 (Office 25.09)
B-1035 Brussels
Tel: + 32 2 800 37 27
Email: international@sprb.brussels
Flanders
Flanders publishes guidance and FAQs on dual-use goods exports.
Applications for export control licences for dual-use goods should be made using the Flanders digital counter. The regional website publishes guidance on using this service.
Exporters who use licences have additional reporting requirements which require them to notify the competent regional authority when the export permits are used.
Government of Flanders,
Department of Foreign Affairs,
88 Avenue du Port, box 80,
B-1000 Brussels
Tel: +32 2 533 48 80
Email: csg@vlaandaren.be
Wallonia
Wallonia publishes guidance on dual-use goods exports.
Applications for export control licences for dual-use goods should be made using the EU’s eLicensing website.
The Walloon government has published guidance for exporters seeking a dual-use goods export licence.
Walloon Public Service DGO6,
14 Chausée de Louvain,
B-5000 Namur
Judgments
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Forum for Peace Action et al v The Flemish Region 2025/69/C
