DENMARK Law and Practice Contributed by: Rikke Sonne, Jakob Skov Bundgaard and Tilde Nielsen Weidinger, Accura
5. Trade and Export Restrictions 5.1 Services The EU sanctions regimes contain multiple import and export bans on services to or from countries such as Russia, Belarus, Iran, North Korea and Myanmar. The EU lifted the majority of its economic sanctions against Syria in May 2025, retaining only targeted security- related restrictions, such as the arms embargo and controls on internal-repression equipment. The nature of the banned services varies depending on the sanctions regime, and on the aim the EU has with the specific sanction. However, the following ser - vices are among others represented in current sanc - tions regimes adopted by the EU: • credit rating services; • services related to LNG projects; • accounting, tax consulting, bookkeeping and auditing services; • IT consultancy services; • banking services; • market research and public opinion polling ser - vices; • reloading services to certain ships; • legal advisory services; • construction, architectural and engineering ser - vices; • business and management consulting services; • services related to specialised financial messaging; • investment services; and • financing or financial assistance, technical assis - tance or brokering services related to prohibited exports of goods. Furthermore, the EU sanctions regime prohibits transactions with, and requires the freezing of assets belonging to, persons or entities that are subject to transaction bans under the different EU sanctions regimes. 5.2 Goods The EU sanctions regimes contain multiple import and export bans on goods to or from countries such as Afghanistan, Haiti, Russia, Belarus, Iran, North Korea, Venezuela and DR Congo. The EU lifted the majority of its economic sanctions against Syria in May 2025,
retaining only targeted security-related restrictions on goods such as arms, internal-repression equipment and cultural property. Similar to bans on services, the nature of the banned goods varies depending on the sanctions regime and the aim that the EU has with the specific sanction. However, the following goods are among others rep - resented in current sanctions regimes adopted by the EU: • aviation and space goods and technologies; • crude oil and petroleum products; • LNG; • oil and gas goods, technologies and products; • arms and dual-use items, as well as advanced goods and technologies; • iron and steel products; • luxury goods, gold, diamonds and jewellery; and • cultural properties. 6. Civil Litigation and Arbitration 6.1 Force Majeure There are no publicly available Danish court decisions that address compliance with sanctions as a bar to the performance of contractual obligations. 6.2 Enforcement Enforcement issues have not been dealt with by the Danish courts.
7. Designation, Compliance and Circumvention 7.1 Executive Body
Denmark does not have a dedicated national body responsible for making autonomous sanctions des - ignation decisions. At the EU level, the Council of the European Union is the decision-making body. The Council adopts restrictive measures through Council Decisions under the Common Foreign and Security Policy (CFSP), typically on the basis of proposals from member states or the High Representative of the Union for Foreign Affairs and Security Policy. These decisions are then implemented through directly
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