Sanctions 2026

DENMARK Trends and Developments 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

Sanctions Remain a Political Priority, With an Apparent Shift Towards Greater Focus on Enforcement 22 February 2026 saw the four-year mark of the Rus- sian invasion of Ukraine, and the days surrounding this date in 2022 also marked the EU’s adoption of the first sanctions packages against Russia in connection with the invasion, with 21 sanctions packages adopted to date. The packages have added individuals, entities, vessels and product categories to an ever-lengthening set of restrictions, along with new instruments and sanctions on important sectors. While new restrictions are likely to be part of upcoming sanctions packages, the 21st package seems to indicate some fatigue as to the practical and political limits of what unanimity will bear, with Greece securing a derogation to continue transporting Russian liquefied natural gas (LNG) to non-EU clients as the most prominent example. Thus, the emphasis in 2025 and 2026 seems somewhat to have shifted from designing new restrictions towards an intent to focus more on enforcing the restrictions already in place. As elaborated further below for Denmark – a small, open, export-dependent economy – this is no longer an abstract shift; it has resulted in the country’s first criminal enforcement for breaching the Russia sanc - tions. Furthermore, a newly proposed “Firewall Act” designed to protect Danish businesses that find them - selves under sanctioned ownership is also making its way through parliament. The Danish government has thus taken action regarding sanctions, as well as having been vocal about expectations for companies, illustrated for example in a minister’s (Morten Bød - skov) comment that companies should do everything

within their power to ensure that their products do not end up in Russia, following revelations that Danish electronics company Bang & Olufsen’s products could be bought in Russia (although no sanctions breaches have been reported in the specific case). Significant Increase in Penalties for Violation of Sanctions Another, more structural, development towards a larger focus on enforcement came with Directive (EU) 2024/1226 on the definition of criminal offences and penalties for the violation of Union restrictive meas - ures, adopted on 24 April 2024 with a transposition deadline of 20 May 2025. For the first time, the EU set common minimum rules on what constitutes a crimi - nal sanctions offence, minimum penalties, corporate liability and limitation periods. Given that most mem - ber states missed the deadline, the European Com - mission opened infringement proceedings against 18 of them on 24 July 2025, which is itself a marker of how seriously Brussels now treats the enforcement gap. That enforcement pressure has continued to escalate. In its March 2026 infringements package, the Commission moved to the next stage of the pro - cess, issuing reasoned opinions – the step preceding possible referral to the Court of Justice of the Euro - pean Union – against Belgium, Bulgaria and Slovenia, which had still not notified full transposition measures more than nine months after the original deadline. Denmark was not one of those countries – even though Denmark was not legally required to transpose the Directive, benefiting from its opt-out from EU Jus - tice and Home Affairs co-operation under Protocol No 22 to the EU Treaties. On 20 June 2025, Law No 731

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