Anti-Corruption 2026

DENMARK Law and Practice Contributed by: Christian Monberg, Simon Evers Hjelmborg, Ann Sophie Juul Hird and Linn Dyrgaard Stinus, Accura Advokatpartnerselskab

When a person accepts an extrajudicial fine, they acknowledge the offence and agree to pay the speci - fied amount, thereby avoiding a court appearance and the legal costs related thereto. It is important to note that accepting an extrajudicial fine is considered an admission of guilt which may have consequences in relation to, for example, future compensation claims as a result of the committed act. In accordance with the principle of access to justice, no person can ever be forced into accepting an extrajudicial fine. 7.5 Recent Landmark Investigations or Decisions Case law involving bribery and corruption in Denmark is relatively sparse. Below the authors have listed three of the most exposed cases involving bribery or corruption in Den - mark from within the past ten years. The Consultancy Case On 18 January 2024, the Eastern High Court of Den - mark delivered a verdict in a significant case involv - ing a former head of department with the national police and a private consultant. The former head of department and the private consultant were accused of engaging in corrupt practices from 2012–2015 dur - ing which the consultant made payments to the for - mer head of department under the guise of consult - ing fees for work allegedly performed by the former head of department for the consultant’s company. The department head was charged with accepting bribes totalling approximately DKK630,000 (approximately EUR85,000) from the consultant (passive bribery), who, in turn, was charged with offering these bribes (active bribery). The former head of department was sentenced to eight months in prison, with six months suspended, while the private consultant received a six-month suspended sentence. Additionally, the department head was ordered to forfeit DKK150,000 (approximately EUR20,000), representing the estimat - ed illicit gains from the corrupt activities. For further details, see the Denmark Trends and Developments article for Chambers Anti-Corruption 2026. The IT Procurement Case In 2015, it was discovered that employees from sev - eral public institutions had received bribes from an

IT supplier. The bribes included luxury trips and din - ners. Several high-ranking officials were implicated, including the former IT-operations manager of one of the public institutions, who received a prison sen - tence of one year and six months for bribery and embezzlement in 2018. Other former executives from the IT company and public officials received various sentences, ranging from conditional impris - onment to community service. The IT company was fined DKK10 million (approximately EUR1.3 million). Almost all of the charged individuals had funds confis - cated. Altogether, around DKK1 million (approximately EUR134,000) was confiscated in the process. The Social Services Case A former employee of the national social services agen - cy embezzled approximately DKK117 million (around EUR15.7 million) over a span of 25 years. The former employee diverted funds intended for social projects into personal accounts. The fraud was uncovered in 2018, leading to the former employee’s arrest in South Africa, and subsequent extradition to Denmark to face trial. During the trial, the former employee admitted to the embezzlement but claimed to be caught in a “vicious circle” and partly motivated by a desire to improve the lives of their three children, who were also charged with handling stolen goods. In February 2020, the former employee was sentenced to six and a half years in prison for their crimes. The court found them guilty of fraud of a particularly grave nature, abusing a public position, and forgery. In addition to the prison sentence, over DKK113 million (approximately EUR15 million) of the individual’s assets were confiscated. 7.6 Level of Sanctions Imposed The level of sanctions differs from case to case depending on the circumstances surrounding the committed offence. As shown in 7.5 Recent Land- mark Investigations or Decisions , prison sentences ranging from a few days to several years are not rare when it comes to these offences and the financial gains achieved through the illicit act will often be con - fiscated. Furthermore, fines will likely be imposed on companies when applicable.

76 CHAMBERS.COM