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In 2025, Dutch enforcement authorities prioritized targeted indictments and penalty orders, with new guidance on self-reporting and cooperation shaping internal investigations. No major law reforms occurred, but notable developments included enhanced privilege protection and expanded powers for the Financial Intelligence Unit. The transportation and financial sectors were key enforcement targets, while consumer protection and environmental crime also saw increased focus.
No major law reforms occurred, but notable developments included enhanced privilege protection and expanded powers for the Financial Intelligence Unit. The transportation and financial sectors were key enforcement targets, while consumer protection and environmental crime also saw increased focus. Cross-border enforcement intensified, highlighted by the first EPPO-led conviction and ongoing sanctions coordination.
Dutch authorities continued their focus on enforcement of white-collar crimes in 2024, particularly regarding sanctions violations, environmental crimes, and tax fraud, scrutinizing the conduct of senior executives in those cases. The Dutch authorities are accelerating investigations and clearing their docket of pending cases, making increased used of out-of-court resolutions.
AO A&O Shearman More A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world.
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