SANCTIONS LISTS AND WATCHLISTS EXPLAINED · GUIDEUPDATED 2026-09-04
    Sanctions Lists and Watchlists Explained

    The Dutch national terrorism list is 118 names in a 14 KB spreadsheet

    Nationale sanctielijst terrorisme: who the Netherlands freezes on its own authority, why most listings date from 2015 to 2017, and what the file omits.

    This is the smallest list in any serious European screening programme and one of the more consequential, because almost everyone on it is Dutch. The Nationale sanctielijst terrorisme is the Netherlands' own terrorism asset-freeze list, made under the Sanctiewet 1977 through the Sanctieregeling terrorisme 2007-II, and it exists because UN Security Council Resolution 1373 obliges states to freeze terrorist assets on national authority rather than waiting for a UN or EU designation. A freeze is imposed by ministerial decision, published in the Staatscourant, and takes effect on publication: bank accounts and cards stop working, and making funds available to a listed person is itself an offence. The file, an OpenDocument spreadsheet of about 14 kilobytes, held 118 listings when we read it on 4 September 2026, in the position stated as of 6 August 2026 — 115 individuals and three organisations, Stichting Al Aqsa, the Rotterdam foundation RAGDER and The Base. The chronology tells the story: 75 of the 118 decisions were taken in 2016 and 2017, at the height of the Syria foreign-fighter caseload. Only one listing has been added since 2020.

    What this workflow covers

    SCOPE
    • 118 listings as at 6 August 2026: 115 natural persons and three organisations.
    • Seven columns and nothing else: surname, given names, alias, date of birth, place of birth, the date of the ministerial decision, and a link to the Staatscourant publication that carries it.
    • Three records carry an alias. Everything else is matched on surname, given names, date of birth and place of birth, which is a thin basis when the surname is Moroccan or Turkish and common in the Netherlands.
    • 39 of the 118 listed people were born outside the Netherlands; the rest give Dutch birthplaces such as Amsterdam, Den Haag, Rotterdam and Nieuwegein. This is a domestic list about domestic residents.
    • Decisions by year: 1 in 2007, 1 in 2011, 1 in 2012, 1 in 2013, 6 in 2014, 18 in 2015, 36 in 2016, 39 in 2017, 2 in 2018, 4 in 2019, 8 in 2020 and 1 in 2024 — the most recent being The Base in January 2024.
    • Download: ned-terrorismelijst.ods from rijksoverheid.nl, roughly 14 KB. No XML, no CSV, no API and no change feed; the file states its own stand van zaken date, and that is the whole freshness mechanism. Each row cites its Staatscourant number, which is the authentic publication and the document to keep in an evidence file rather than the spreadsheet row.
    • No EU or UN designation appears here. The EU terrorism list under Common Position 2001/931 and the UN 1267 list are separate instruments, and a Dutch institution screens all three.
    • Sparse identifiers make bad matches likely here: a Dutch bank matching on surname plus given name alone will hit unrelated namesakes, and only the date of birth reliably separates them.
    • A match freezes the relationship and triggers a report to the Ministry of Finance; making funds available, including by a family member, is prohibited. The Dutch national terrorism list is a registered source on our coverage page alongside the EU and UN terrorism designations.

    Key statistics

    DATA
    Listings as at 6 August 2026
    118 (115 individuals, 3 organisations)
    Counted from ned-terrorismelijst.ods
    Decisions taken in 2016 and 2017
    75 of 118
    Counted from ned-terrorismelijst.ods
    Records carrying an alias
    3 of 118
    Counted from ned-terrorismelijst.ods

    Compliance glossary

    TERMS
    Nationale sanctielijst terrorisme
    The Dutch national list of persons and organisations whose assets are frozen by ministerial decision on terrorism grounds, separate from EU and UN terrorism designations.
    Sanctiewet 1977
    The Dutch framework statute for implementing international sanctions and for making national sanctions regulations, including the Sanctieregeling terrorisme 2007-II.
    Staatscourant
    The Netherlands Government Gazette. A Dutch freeze takes effect on publication there, and the gazette reference is the authentic record of the decision.
    Resolution 1373
    The 2001 Security Council resolution requiring every state to criminalise terrorist financing and to freeze terrorist funds on its own authority, without a UN listing.

    Authoritative references

    SOURCES

    Frequently asked questions

    Q&A
    Q.01
    Why does the Netherlands keep a national terrorism list at all?
    Because UN Security Council Resolution 1373 requires states to freeze terrorist funds on their own authority, without waiting for a UN committee to act. National listing lets the Netherlands move against a resident within days of an intelligence assessment, where an EU or UN designation would take months and might never happen for a purely domestic case.
    Q.02
    How many people are on the Dutch national terrorism list?
    118 as at 6 August 2026, of which 115 are individuals and three are organisations. The list has been broadly static since 2020: eight decisions that year and one since, when The Base was listed in January 2024. It is not a list that changes weekly, which makes a monthly refresh reasonable.
    Q.03
    Where can I download the nationale sanctielijst terrorisme?
    As an OpenDocument spreadsheet, ned-terrorismelijst.ods, from the Rijksoverheid document page for the nationale terrorismelijst. It is about 14 KB, carries its own position date in the first row, and is the only machine-readable form the government publishes. No API exists.
    Q.04
    What happens to someone who is listed?
    Their funds and economic resources are frozen from the moment the decision is published in the Staatscourant. They lose access to bank accounts and cards, and it is an offence for anyone, including relatives, to make money available to them. A listing can be challenged, and delisting is a ministerial decision published the same way.
    Q.05
    Do I need this list if I already screen the EU terrorism list?
    If you have Dutch customers, yes. The national list exists to catch people the EU has not designated, so by construction it contains names the EU list does not. A Dutch retail bank screening only EU and UN sources would miss the entire domestic population this instrument was created for.
    Q.06
    How should a bank handle a name-only match on this list?
    As a candidate, not a finding. With only three aliases across 118 records and common Dutch-Moroccan and Dutch-Turkish surnames on the file, name similarity alone proves very little. Compare the date of birth and place of birth, and if the customer record lacks both, escalate for identity verification rather than acting on the name.