Sanctions Law & Internal Investigations

Charlotte Posthuma

+31 73 692 77 30

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In the society that is becoming more and more complex the role of supervision and regulation is getting bigger. Your company has to deal with this. Our specialists are well versed in this and guide you to a discrete solution, in which your reputation will be preserved. In administrative cases as well as in criminal cases.

Criminal law

Criminal law can deeply interfere in your company. We are specialized in fraud and corruption (bribery, money laundering, Money Laundering and Terrorist Financing (Prevention) Act, forgery of documents), industrial accidents and the environmental criminal law (including the Fertilizers Act and Major Accidents (Risks) Decree). For instance, you might have to deal with the Netherlands Labour Authority, Public Prosecution Service, the Netherlands Food and Consumer Product Safety Authority or the Fiscal Intelligence and Investigation Service. We provide expert legal assistance which is required in these cases. We have many years of experience in handling criminal cases, in which the principle always is the prevention of criminal prosecution.

Penalty and Sanctions law

If your company is involved in a penalty procedure, our combined knowledge of criminal and administrative law is of essential importance. Punishment can take place under criminal law, but also under administrative law. In order to advise properly and to examine the consequences of these different penalty procedures for your company (for instance consequences under the Public Administration (Probity Screening) Act), adequate legal assistance is essential. A penalty is a frequently occurring way of settlement in such cases as industrial accidents where a suspicion of having violated the Working Conditions Act exists.

Internal investigations practice

Our company can be confronted with for instance a suspicion of fraud in the financial statements, a suspicion of criminal offences or a suspicion of integrity violations (including transgressive behaviour). It might be necessary to form a correct picture of what has happened factually. We carry out an investigation in a discreet way, and advise you how to deal with alleged violations. In this way, your company can continue after for instance a suspicion of fraud in the financial statements (obtain an unqualified opinion of the auditor), or you can by means of the investigation rebut the suspicion of criminal offences. Sometimes it is in your own interest to address the authorities after concluding an investigation. We also provide legal assistance in cases of self-reporting.

International sanctions

Our specialists can provide assistance and advice with regard to international/European sanctions against states, legal entities, organisations and individuals. These include the sanctions against Russia in reply to the war against Ukraine. Does your company have an involvement with sanctioned territories (for example import and export) or individuals? Always obtain legal advice, you can overlook things easily in this complex legislation and regulations. To act in violation of the sanctions law is a (European) crime. Charlotte Posthuma gives lectures on this and appears in the national media to inform about the scope of these sanctions (NPO Radio 1).