Who was sanctioned, and for what?

A lily and tulip grower with an average of around 50 (at peak 75) employees, where Polish migrant workers are employed (anonymised in the judgment), was unable to produce sufficient records of hours worked and wages paid for 18 employees for September 2020 to February 2021. The Dutch Minister of Social Affairs and Employment (Minister van Sociale Zaken en Werkgelegenheid) imposed 118,000 EUR in 2024 (112,100 EUR after objection); the North Netherlands District Court (Rechtbank Noord-Nederland) reduced the fine to 95,587.50 EUR, partly because of measures taken and excessively long proceedings.

Authority / court

Rechtbank Noord-Nederland (Bußgeld: Minister van Sociale Zaken en Werkgelegenheid / Nederlandse Arbeidsinspectie)

Area of law

Health and safety and employment law · Minimum wage and undeclared work

Legal basis

Art. 18b Abs. 2 Wet minimumloon en minimumvakantiebijslag (Wml)

Action

Fine

Status of proceedings

reduced

Sector

Food and agriculture

Employees

50 to 249

Mitigating circumstances

Reduction of 12.5 % for appropriate measures, 5 % for delay and 2,500 EUR for exceeding the reasonable length of proceedings.

Checked against the official source on 25 Sep 2026 · Direct link

The Nederlandse Arbeidsinspectie (Netherlands Labour Authority) imposed fines totalling 316,875 EUR on a gym chain in Amsterdam that is not named in the release. For 25 foreign workers the required work permit or combined residence and work permit was missing, and for three people identity had not been established (Wav, Foreign Nationals Employment Act, 234,375 EUR); because of deficient records it could not be verified whether the minimum wage had been paid for all hours worked (WML, Minimum Wage and Minimum Holiday Allowance Act, 60,000 EUR), plus a breach of the Arbeidstijdenwet (Working Hours Act, 22,500 EUR). The company also received two warnings that work may be preventively halted if the same or similar breaches recur.

Authority / court

Nederlandse Arbeidsinspectie

Area of law

Health and safety and employment law · Minimum wage and undeclared work

Legal basis

Wet arbeid vreemdelingen (Wav); Wet minimumloon en minimumvakantiebijslag (WML); Arbeidstijdenwet (ATW)

Action

Fine

Status of proceedings

unknown

Sector

Other

Published

24 Aug 2026

Checked against the official source on 2 Oct 2026 · Direct link

The Nederlandse Arbeidsinspectie (Netherlands Labour Authority) imposed fines totalling 153,300 EUR on a platform for freelancers and nine companies that used it to deploy foreign workers without a right to work in hospitality and education: 146,500 EUR under the Wav (Foreign Nationals Employment Act) (platform 66,000 EUR, the nine hirers 4,000 to 27,000 EUR each, together 80,500 EUR) and 6,800 EUR under the Waadi (Placement of Personnel by Intermediaries Act) (platform 3,400 EUR, two hirers 2,000 and 1,400 EUR). The platform regarded itself merely as an intermediary; based on how it actually operated, the Labour Authority classed it as an employer under the broad Wav definition.

Authority / court

Nederlandse Arbeidsinspectie

Area of law

Health and safety and employment law · Minimum wage and undeclared work

Legal basis

Wet arbeid vreemdelingen (Wav); Wet allocatie arbeidskrachten door intermediairs (Waadi)

Action

Fine

Status of proceedings

unknown

Sector

Media and online platforms

Published

13 Aug 2026

Checked against the official source on 2 Oct 2026 · Direct link

On 2 June 2026 the Autoriteit Financiële Markten (AFM, Dutch Authority for the Financial Markets) fined bunq B.V. 170,000 EUR because in seven cases the bank did not give a substantive reply within the statutory 15 working days to complaints from customers who had fallen victim to online fraud (November to December 2023 and April to at least August 2024). Because bunq fully or largely compensated those affected without being legally obliged to, the AFM lowered the base amount from 500,000 to 200,000 EUR; the simplified settlement brought a further 15% reduction.

Authority / court

Autoriteit Financiële Markten (AFM)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Art. 43a Abs. 1 i. V. m. Abs. 2 Besluit Gedragstoezicht financiële ondernemingen Wft (BGfo), Umsetzung von Art. 101 PSD2

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

Voluntary full or largely full compensation of the customers concerned; simplified settlement (−15%).

Published

8 Jun 2026

Checked against the official source on 2 Oct 2026 · Direct link

In September 2024 three construction companies coordinated their bid prices and decided the winner in a civil engineering tender of the municipality of Ommen, which was awarded for 153,250 EUR. Because of earlier cartel infringements by the companies or their legal predecessors established in 2005, the ACM (Autoriteit Consument & Markt, Dutch competition and consumer authority) increased the fines by 20%. In the simplified procedure it imposed allegedly 30,000 EUR on Timmerhuis and allegedly 15,500 EUR on Bouwhuis (45,500 EUR in total); Van Gelder, as first leniency applicant, was not fined.

Authority / court

Autoriteit Consument & Markt (ACM)

Area of law

Competition law · Cartels and collusion

Legal basis

Art. 6 Abs. 1 Mededingingswet

Action

Fine

Status of proceedings

unknown

Sector

Construction and real estate

Repeat case

yes

Mitigating circumstances

For cooperating in the simplified procedure, the ACM reduced the fines of Bouwhuis and Timmerhuis by 15%, and that of Timmerhuis by a further 5% for evidence provided voluntarily; Van Gelder, as first applicant, received full leniency immunity.

Published

2 Jun 2026

Checked against the official source on 4 Oct 2026 · Direct link

On the auction website Ticketveiling.nl, House of Tickets B.V. drove up the prices of auctioned lots with automatic bids placed by an algorithm and misled consumers about how the final price came about. The ACM (Autoriteit Consument & Markt, Dutch competition and consumer authority) considered 300,000 EUR appropriate and reduced the fine by 10% to 270,000 EUR because the company admitted the infringements in the simplified procedure; it decided not to fine Ticketveiling B.V.

Authority / court

Autoriteit Consument & Markt (ACM)

Area of law

Consumer protection and online retail · Misleading advertising and pricing

Legal basis

Art. 8.8 Whc i. V. m. Art. 6:193c Abs. 1 lit. d und Art. 6:193g lit. v BW

Action

Fine

Status of proceedings

unknown

Sector

Retail and e-commerce

Mitigating circumstances

10% reduction for admitting the infringements and cooperating in the simplified procedure; the infringements were short and ended voluntarily before the investigation began.

Published

28 May 2026

Checked against the official source on 2 Oct 2026 · Direct link

On 20 April 2026 the Autoriteit Financiële Markten (AFM, Dutch Authority for the Financial Markets) fined the US asset manager Arrowstreet Capital, Limited Partnership 297,000 EUR because, between July 2020 and November 2024, an error in its calculation method led it to report its net short positions in Just Eat Takeaway.com and Galapagos to the AFM too low on 101 occasions, 85 of which also breached the public disclosure obligation. Because the firm reported the error itself, corrected it quickly, cooperated fully and took measures against recurrence, the AFM reduced the base amount by 30%; the simplified settlement brought a further 15% reduction, and the matter is closed.

Authority / court

Autoriteit Financiële Markten (AFM)

Area of law

Capital markets and financial supervision · Disclosure and reporting obligations

Legal basis

Art. 5 Abs. 1 und Art. 6 Abs. 1 Verordnung (EU) Nr. 236/2012 (Leerverkaufsverordnung, SSR)

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

Self-reporting, prompt correction, full cooperation and measures against recurrence (−30% on the base amount); simplified settlement (−15%).

Published

22 Apr 2026

Checked against the official source on 2 Oct 2026 · Direct link

In 2023 PostNL delivered only 89.48% of letters with a five-day delivery obligation under the universal postal service on time, instead of the statutory 95%. The ACM (Autoriteit Consument & Markt, Dutch competition and consumer authority) rejected the force majeure argument based on the tight labour market and imposed a fine of 6,923,000 EUR.

Authority / court

Autoriteit Consument & Markt (ACM)

Area of law

Other

Legal basis

Art. 16 Abs. 6 Postwet 2009 i. V. m. Art. 4a Postbesluit 2009

Action

Fine

Status of proceedings

unknown

Sector

Transport, logistics and shipping

Published

12 May 2026

Checked against the official source on 2 Oct 2026 · Direct link

Amsterdam-based Ridetech offered the ride-hailing app Yango in Finland and Norway and transferred data of drivers and customers to the group companies Yandex.Taxi LLC and Yandex LLC in Russia without demonstrating appropriate safeguards. The Autoriteit Persoonsgegevens (Dutch Data Protection Authority, AP) imposed 100 million EUR on the legal successor and prohibited further transfers to Russia.

Authority / court

Autoriteit Persoonsgegevens (AP)

Area of law

Data protection · International data transfers

Legal basis

Art. 44, Art. 46 iVm Art. 5 Abs. 1 lit. a und Abs. 2 DSGVO

Action

Fine

Status of proceedings

unknown

Sector

Transport, logistics and shipping

Checked against the official source on 25 Sep 2026 · Direct link

Hakrinbank N.V., Finabank N.V. and De Surinaamsche Bank N.V. concluded transactions (out-of-court settlements) with the Openbaar Ministerie (OM, Dutch Public Prosecution Service) over suspected negligent money laundering (schuldwitwassen) in 2018 and are paying a total of 415,000 EUR (Hakrinbank 166,000 EUR, Finabank and De Surinaamsche Bank 124,500 EUR each). The trigger was the seizure at Schiphol Airport in April 2018 of 19.5 million EUR in cash belonging to the three banks and bound for Hong Kong; the OM accused them of not having adequately checked the origin of the cash in Suriname, in particular who the customers of the bureaux de change among their clients were. The OM found no intent; it took into account the age of the case and the lesser seriousness of negligent money laundering, and the seized money will be returned.

Authority / court

Openbaar Ministerie (OM), Arrondissementsparket Noord-Holland

Area of law

Money laundering and terrorist financing · Customer due diligence

Legal basis

Schuldwitwassen (fahrlässige Geldwäsche nach niederländischem Strafrecht); Transaktion des OM

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Culpability

negligent

Mitigating circumstances

No intent established; age of the case; the banks have since implemented improvements in cash controls, KYC and governance.

Published

17 Mar 2026

Checked against the official source on 2 Oct 2026 · Direct link

The Openbaar Ministerie (OM, Dutch Public Prosecution Service) imposed penalty orders totalling 1,125,000 EUR on four companies from Barneveld that belonged to the same group at the time and are not named in the releases, consisting of 660,000 EUR in fines and 465,000 EUR in confiscation of unlawfully obtained gains. According to the OM, between 2013 and 2016 the firms accepted excessively contaminated sand, cleaned it inadequately or incorrectly and deliberately mixed it with cleaner sand for reuse, in breach of permit conditions and the Wet milieubeheer (Environmental Management Act) and involving forgery. The companies initially lodged an objection (verzet) but withdrew it, so the penalty orders are final (release of 2 July 2026).

Authority / court

Openbaar Ministerie (OM), Functioneel Parket

Area of law

Environment and sustainability · Waste and hazardous substances

Legal basis

Vorschriften der Umgebungsgenehmigungen (omgevingsvergunningen); Wet milieubeheer; valsheid in geschrift; Strafbefehle des OM

Action

Fine

Status of proceedings

final

Sector

Other

Culpability

intentional

Mitigating circumstances

The companies have adapted or ceased their activities, and measures have been taken within the group.

Published

10 Mar 2026

Checked against the official source on 2 Oct 2026 · Direct link

According to the Dutch Public Prosecution Service (OM), the top holding company of a mining, oil and gold group, which was based in the Netherlands from 2010 to 2017, participated together with others in bribing public officials of the DR Congo in order to obtain licences for cobalt and copper mines. On 6 March 2026, the OM issued a strafbeschikking (prosecutorial penalty order) imposing a fine of 25.8 million EUR, which Fleurette accepted.

Authority / court

Openbaar Ministerie (OM); Ermittlungen FIOD Anti-Corruptie Centrum

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Buitenlandse ambtelijke omkoping (Wetboek van Strafrecht); OM-strafbeschikking

Action

Fine

Status of proceedings

final

Sector

Steel and metals

Culpability

intentional

Published

10 Mar 2026

Checked against the official source on 25 Sep 2026 · Direct link

The Openbaar Ministerie (OM, Dutch Public Prosecution Service) imposed a penalty order of 500,000 EUR on the Dutch Louis Vuitton BV for breaches of the Wwft (Dutch Anti-Money Laundering and Anti-Terrorist Financing Act) because, over a long period, the company did not sufficiently check who the customers were who repeatedly spent large amounts in cash. The case arises from ongoing money laundering proceedings in which, according to the OM, a buyer spent a total of more than 2 million EUR of criminal proceeds under various names on luxury goods in shops such as those of Louis Vuitton between August 2021 and February 2023 and sent the bags to China for resale; a then sales employee allegedly helped her and warned her whenever she was about to spend more than 10,000 EUR a month through one of her customer accounts. The OM settled the matter out of court to free up scarce hearing capacity at the Rechtbank Rotterdam (Rotterdam District Court).

Authority / court

Openbaar Ministerie (OM), Landelijk Parket

Area of law

Money laundering and terrorist financing · Customer due diligence

Legal basis

Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft), Kundenprüfung; Strafbefehl des OM

Action

Fine

Status of proceedings

unknown

Sector

Retail and e-commerce

Published

12 Feb 2026

Checked against the official source on 2 Oct 2026 · Direct link

To secure a share in the Riyadh Metro project, around 31 million USD was paid between 2013 and 2021 to an agent representing a high-ranking member of the Saudi royal family; the agent payments were understated to the export credit insurer Atradius. Strukton accepted a transaction (out-of-court settlement) of 10 million EUR.

Authority / court

Openbaar Ministerie (OM)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Buitenlandse ambtelijke omkoping und valsheid in geschrift (Wetboek van Strafrecht); Transactie nach Art. 74 Sr

Action

Fine

Status of proceedings

final

Sector

Construction and real estate

Culpability

intentional

Mitigating circumstances

Cooperation from mid-2023; compliance programme in place since 2017; the employees involved are no longer with the company.

Published

30 Mar 2026

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

Ten municipalities (Delft, Ede, Eindhoven, Gooise Meren, Haarlemmermeer, Hilversum, Huizen, Tilburg, Veenendaal and Zoetermeer) had received, stored and used analyses of the local Islamic community prepared by an external research firm (mostly so-called power-field analyses, in Haarlemmermeer a quick scan), which also contained information on the religion and other sensitive characteristics of individuals. On 3 February 2026 the AP (Autoriteit Persoonsgegevens, Dutch data protection authority) imposed 25,000 EUR on each board in separate decisions (250,000 EUR in total); for seven municipalities it also restricted further processing of the analyses to handling data subject rights and court proceedings.

Authority / court

Autoriteit Persoonsgegevens (AP)

Area of law

Data protection

Legal basis

Art. 5 Abs. 1 lit. a i. V. m. Art. 6 Abs. 1 und Art. 9 Abs. 1 DSGVO (AVG); Verarbeitungsbeschränkung nach Art. 58 Abs. 2 DSGVO (sieben Bescheide)

Action

Fine

Status of proceedings

unknown

Sector

Public sector

Published

5 Feb 2026

Checked against the official source on 2 Oct 2026 · Direct link

Until March 2018, the payment institution had no systematic integrity risk analysis (SIRA) and therefore no systematic identification and analysis of integrity risks for its gatekeeper function. The Dutch central bank (De Nederlandsche Bank, DNB) imposed the fine in 2020; following objection and appeal proceedings, it was fixed at the reduced amount of 406,125 EUR by the decision of 28 January 2026 and was published in July 2026.

Authority / court

De Nederlandsche Bank (DNB)

Area of law

Money laundering and terrorist financing · Internal controls

Legal basis

Art. 3:10 Wet op het financieel toezicht (Wft); Art. 10 Besluit prudentiële regels Wft (Bpr)

Action

Fine

Status of proceedings

reduced

Sector

Financial services and insurance

Mitigating circumstances

Fine reduced in the objection and appeal proceedings

Published

21 Jul 2026

Checked against the official source on 25 Sep 2026 · Direct link

In May/June 2022, the working time records of an asparagus business (anonymised in the judgment) deviated structurally from the hours actually worked; among other things, Sunday work went unrecorded, so compliance with working and rest times could not be checked. The Administrative Jurisdiction Division of the Dutch Council of State (Raad van State, Afdeling bestuursrechtspraak) upheld the fine of 11,250 EUR, imposed in 2023 without prior warning, including the increase factor of 1.5.

Authority / court

Raad van State, Afdeling bestuursrechtspraak (Bußgeld: Minister van Sociale Zaken en Werkgelegenheid)

Area of law

Health and safety and employment law · Working time

Legal basis

Art. 4:3 Abs. 1 Arbeidstijdenwet

Action

Fine

Status of proceedings

final

Sector

Food and agriculture

Checked against the official source on 25 Sep 2026 · Direct link

In 2021, a hacker gained access via a web form to a web server and a database server of the university, obtained, among other things, names with passwords and citizen service numbers of students and staff, and unsuccessfully demanded a ransom. According to the Dutch data protection authority (Autoriteit Persoonsgegevens, AP), security was not aligned with the risks, and the rights of a database account were not restricted.

Authority / court

Autoriteit Persoonsgegevens (AP)

Area of law

Data protection · Data breaches and data security

Legal basis

DSGVO Art. 32

Action

Fine

Status of proceedings

final

Sector

Public sector

Culpability

negligent

Mitigating circumstances

Settlement without objection; active damage limitation, strengthened resilience and sharing of lessons learned with other organisations.

Published

17 Dec 2025

Checked against the official source on 25 Sep 2026 · Direct link

The Openbaar Ministerie (OM, Dutch Public Prosecution Service) imposed a penalty order of 130,500 EUR on TMF Management B.V. because the trust office did not immediately report two unusual transactions by a client to FIU-NL in 2020 and 2021. TMF continued to work on the (re)structuring of that client’s bond issue although, from 2020, it was aware of negative media reports about pending court cases over suspected fraud by the client; the proceedings stemmed from a report by De Nederlandsche Bank (Dutch central bank). Because of the exemplary role of the internationally active trust office, the OM raised the fine category and granted a 25% reduction for voluntary, full and timely cooperation.

Authority / court

Openbaar Ministerie (OM), Functioneel Parket

Area of law

Money laundering and terrorist financing · Suspicious activity reports

Legal basis

Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft), Pflicht zur unverzüglichen Meldung ungewöhnlicher Transaktionen; Strafbefehl des OM

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Mitigating circumstances

Voluntary, full and timely cooperation (−25%).

Published

13 Nov 2025

Checked against the official source on 2 Oct 2026 · Direct link

On 12 November 2025 the Autoriteit Financiële Markten (AFM, Dutch Authority for the Financial Markets) issued a direction (aanwijzing) to Euronext Amsterdam N.V. as operator of the regulated markets because, in the AFM’s view, three conditions of its announced new settlement model for market participants wishing to use a central securities depository (CSD) other than Euronext Securities Milan restricted such CSDs’ access to the transaction feeds. Euronext thereby breached the obligation to provide non-discriminatory and transparent access under Art. 53(1) CSDR. Euronext withdrew the conditions and confirmed access for the CSDs concerned; the direction is final.

Authority / court

Autoriteit Financiële Markten (AFM)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Art. 53 Abs. 1 Verordnung (EU) Nr. 909/2014 (CSDR); Anweisung nach Art. 1:75 Abs. 1 i. V. m. Art. 1:3a Abs. 1 Wet op het financieel toezicht (Wft)

Action

Order

Status of proceedings

final

Sector

Financial services and insurance

Published

13 May 2026

Checked against the official source on 2 Oct 2026 · Direct link