Yes. A bank that receives SEPA Direct Debits to debited to, or SEPA Credit Transfers to be credited to its clients and submitted by a single known and verified counterparty may perform risk-based examinations of such transactions (regular checks). In doing so, the bank must ascertain that there is minimal risk that a financial service or transaction will cause financial assets to be made available to any person or entity mentioned in the Sanctions Regulations.
Since 1 February 2014, credit transfers and direct debits have been subject to new rules encased in the European Single Euro Payment Area or SEPA Regulation. SEPA intends to create a single European market for euro payment services. To this end, euro payments have been standardised, removing the distinction between a domestic euro payment and a euro payment to or from another SEPA country.
After the introduction of SEPA, the number of cross-border payments is expected to increase. This is because corporations that operate in several SEPA countries may find it easier to concentrate their financial administration in one location. Think, for instance, of an energy supplier or telephone company that collects all client payments within the SEPA area through a single bank in that area. The expected increase prompts the following question.
Sanctions Regulations aim to maintain or restore international peace and security, to strengthen the international rule of law and to combat terrorism. More specifically, Sanctions Regulations relating to the financial system (i.e. financial sanctions) aim to prevent financial assets to be or become available, directly or indirectly, to the persons or entities mentioned in the Sanctions Regulations. An institution must at all times be able to detect whether the the Sanctions Regulations refer to a client or to a service provided. Also, a financial undertaking or pension fund in the Netherlands must be able to inform, and must inform, DNB without delay of such a finding. These requirements cannot be adhered to in a risk-based manner, meaning that institutions have no say in whether Sanctions Regulations are invoked. The process whereby names are checked against the Sanctions Regulations (e.g. manual or digital) and the frequency with which this happens, however, does permit a risk-based approach. This is apparent from the explanatory notes to the Sanctions Act 1977 (Supervision) Regulation (Regeling Toezicht Sanctiewet 1977) and to the DNB Guidance on the Anti-Money Laundering and Anti-Terrorist Financing Act and the Sanctions Act (DNB Leidraad Wwft en Sanctiewet).
The principle underlying the Regulation is that a bank in the Netherlands (Bank A in the figure below) checks both counterparties against the sanctions lists for every financial transaction it performs. However, if Bank A regularly checks both its own clients and the counterparty (i.e. the SEPA Bank's client in the figure) against the sanctions lists, it does not have to do so for every individual transaction between the two. The frequency of such checks can be set on a risk-oriented basis, provided that the bank ascertains that there is minimal risk that a financial service or transaction will cause financial assets to be made available to any person or entity mentioned in the Sanctions Regulations. An example of such a transaction involving minimal risk is the monthly direct debit collection from clients of Bank A by a foreign mobile telephone provider.
 The SEPA countries are the Member States of the European Union, those of the EEA (Norway, Iceland and Liechtenstein), Switzerland, Monaco and San Marino.