DENMARK Law and Practice Contributed by: Rikke Sonne, Jakob Skov Bundgaard and Tilde Nielsen Weidinger, Accura
2.2.4 Criminal Enforcement Action In October 2025, Alfa Laval Denmark (a subsidiary in the Alfa Laval group) pleaded guilty to having attempt - ed, on two occasions in 2022, to export centrifuge parts to Russia that could “contribute to strengthen - ing Russian industrial capacity”. The products were classified as dual-use and comprised spare parts for a centrifuge valued at just over DKK500,000, which had been sold to a sister company in Russia. Alfa Laval Denmark was fined DKK100,000, marking the first time a Danish company has been penalised for breaching the EU sanctions against Russia since they were adopted in 2022. The case was heard as a Prior to any breach, organisations at risk should adopt, and regularly update, compliance pro - grammes, including creating robust risk assessments and due diligence processes. Besides reducing the risk of inadvertently breaching sanctions, it may also serve to demonstrate the absence of intent or gross negligence if sanctions are breached. If a breach has occurred, voluntary disclosure, commitment to rectify - ing the issue, and co-operating with authorities may serve as mitigating factors. 2.2.6 Strict Liability The Danish sanctions regime does not operate on the basis of strict liability but rather requires that a breach be committed either intentionally or through negligence. It is possible to obtain authorisations and derogations from sanctions, but only on the specific grounds set out in the applicable EU regulation. Typical grounds include: • the release of frozen funds to cover basic needs; • reasonable professional fees; • extraordinary expenses; • the satisfaction of pre-existing contractual obliga - tions; and • humanitarian purposes. confession case. 2.2.5 Mitigation 2.3 Licensing 2.3.1 Derogation
ity has responsibilities within their separate areas of expertise. Some of the main regulators/authorities include:
• the Danish Business Authority; • the Danish Customs Agency; • the Danish Maritime Authority;
• the Danish Financial Supervisory Authority; and • the Danish Civil Aviation and Railway Authority. 2.2 Enforcement 2.2.1 Enforcement Responsibilities Civil enforcement is generally not available under Dan - ish law, although the legal basis can vary from author - ity to authority. Where a legal basis for civil enforce - ment does exist, the relevant sector authorities are each responsible within their areas; see 2.1 Primary Regulators . Cases regarding potential breaches of sanctions commonly begin at the sector authorities, who may then choose to file a police report, handing over the case to criminal enforcement. Criminal enforcement is initially handled by the Dan - ish Security and Intelligence Service ( Politiets Efterret- ningstjeneste , PET). If the PET chooses not to pursue the case, it is then delivered to the National Special Crime Unit ( National Enhed for Særlig Kriminalitet , NSK). 2.2.2 Breaching Sanctions Breaching sanctions is considered a criminal offence pursuant to Section 110c of the Danish Criminal Code, which is located within the chapter of the code con - cerning treason and other offences against the inde - pendence and security of the State. Breaches may result in fines or imprisonment of up to five years or eight years under aggravating cir - cumstances, following Act No 731 of 20 June 2025 amending the Danish Criminal Code, which increased these penalties; see 1.2 Key Trends . Negligent sanc - tions breaches may lead to fines or imprisonment for up to three years. 2.2.3 Civil Enforcement Action There are no known civil enforcement actions in respect of sanctions breaches.
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