DENMARK Law and Practice Contributed by: Rikke Sonne, Jakob Skov Bundgaard and Tilde Nielsen Weidinger, Accura
Accura Accura Advokatpartnerselskab Alexandriagade 8 2150 Nordhavn Denmark Tel: +45 3945 2800 Email: INFO@ACCURA.dk Web: www.accura.dk
1. Trends and Overview 1.1 Sanctions Market
The latest sanctions package – the 21st – was adopt - ed on 23 July 2026. The package targets Russia and Belarus, as well as circumvention via Kazakhstan, Kyrgyzstan, China, Turkey, the United Arab Emir - ates (UAE) and India, across energy, finance/crypto, trade, maritime transport and fisheries. Key measures include: • bank and crypto transaction bans; • an oil price cap freeze; • expanded shadow-fleet vessel listings; • new export and import restrictions; • first-ever fisheries sanctions; and • the basis for a future entry ban for former Russian combatants. 1.2 Key Trends Sanctions remain a priority for the Danish govern - ment, as particularly evidenced by the introduction of new legislative measures as well as by statements from officials. Thus, in the past year, Denmark has increased the statutory penalty framework applicable to breaches of sanctions, specifically the increase in the penalty ceil - ing under Section 110c(2) of the Danish Criminal Code introduced by Act No 731 of 20 June 2025 amend - ing the Criminal Code, which entered into force on 21 June 2025. Prior to the amendment, the ordinary maximum penalty for breaching sanctions regulations was four months’ imprisonment, rising to four years’ imprisonment where particularly aggravating circum - stances were present. The new provision raises these ceilings to five years’ imprisonment for ordinary viola -
The Danish sanctions sector continues to be particu - larly influenced by sanctions relating to the war in Ukraine. EU sanctions have continued to expand over the last 12 months as a result of sanctions packages (the 18th, 19th, 20th and 21st packages) imposed by the EU in the context of the war in Ukraine. The 20th sanctions package in particular was rather broad, and extended the EU’s Russia sanctions regime through a further 120 designations, with particular emphasis on the energy sector, military-industrial actors and third-country intermediaries. The package also broadened measures targeting Russia’s shadow fleet, imposing service prohibitions on a further 46 vessels. New energy-related restrictions were intro - duced, including prohibitions on certain services sup - plied to Russian liquefied natural gas (LNG) projects. The package further tightened anti-circumvention measures, marking – rather significantly – the first use of the EU’s anti-circumvention instrument, directed at Kyrgyzstan. On 15 June 2026, a separate “mini” listing package was adopted, followed later that month by a 12-month renewal of existing sanctions, while the 21st sanctions package was still being negotiated. This may suggest a different approach to adopting sanctions being on the table for future sanctions – enabling swifter actions and making it more difficult to stall an entire package due to special interests.
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