DENMARK Law and Practice Contributed by: Rikke Sonne, Jakob Skov Bundgaard and Tilde Nielsen Weidinger, Accura
Applications are made to the relevant Danish compe - tent authority, such as the Danish Business Author - ity or the Danish Financial Supervisory Authority, depending on the measure concerned. The authority assesses each application against the conditions in the regulation, and derogations cannot be granted beyond what EU law permits. 2.3.2 Provision of Legal Services There is no general licence for the provision of legal services to designated persons, but certain exemp - tions apply, including derogations intended to safe - guard a designated person’s right to an effective remedy and to a fair trial, such as the payment of reasonable professional fees and reimbursement of incurred expenses associated with the provision of such legal services. 2.4 Reporting There are several reporting obligations in the EU reg - ulations, most notably the obligation on natural and legal persons to report, without delay, any funds or economic resources frozen or any information that would facilitate compliance with the applicable EU regulation. Such reports must generally be made to the relevant Danish competent authority (in most cas - es, the Danish Business Authority). 3. Recent and Future Legal Developments 3.1 Significant Court Decisions or Legal Developments Overall, the picture emerging seems to be that enforcement is intensifying in Denmark, albeit from modest levels. In October 2025, Alfa Laval Denmark (a subsidi - ary in the Alfa Laval group) pleaded guilty to hav - ing attempted, on two occasions in 2022, to export centrifuge parts to Russia that could “contribute to strengthening Russian industrial capacity”; see 2.2.4 Criminal Enforcement Action . Furthermore, a much- awaited case regarding the Danish paint group Flüg - ger, accused of having continued to sell paint to Rus - sian customers via distributors in third countries in breach of sanctions, is expected to be heard in the
near future. Flügger, the company’s CEO as well as their CFO have all been charged with sanctions breaches. More recently, on 8 July 2026, the NSK, in co-operation with the PET, arrested and charged two men in a case concerning breaches of trade sanctions against Russia. The increased focus on enforcement also seems to be reflected in the (heightened) media attention within this area. In recent years, Danish media has placed greater focus on possible sanctions breaches among Danish companies that have previously traded with Russia, in turn creating more pressure on companies to ensure sanctions compliance. As an example, the Danish electronics company Bang & Olufsen (B&O) has recently been mentioned in media coverage in connection with sanctioned products that could still be found on the Russian market. In April 2026, it was thus revealed that brand-new, sanctioned B&O speakers and headphones were being sold openly in both physical stores and online in Russia. B&O subsequently acknowledged “challenges” with the continued sales and distanced itself from the situ - ation, while a government minister publicly seemed to reprimand the company. B&O has stated that the company has no dealer agreements in Russia and has required its authorised dealers to comply with EU sanctions. On 1 May 2026, the Danish company FLSmidth published a press release disclosing that it is inves - tigating a potential breach of the Russia sanctions regime. According to the company, findings from an internal review indicate that an infringement may have occurred. The matter relates, inter alia, to the fact that “certain draft pre-contractual tender materials were provided to individuals in Russia in connection with a limited number of prospective projects in Kazakh - stan”, as well as to services falling within the scope of the applicable sanctions regulations. Further, the com - pany announcement stated that FLSmidth intends to notify the relevant authorities and co-operate fully in any subsequent proceedings. Another significant legal development happened on 31 May 2026, when an executive order entered into force transposing sanctions packages up to and including
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