SWEDEN Law and Practice Contributed by: Anders Leissner, Martin Johansson, Isak Lefvert and Imola Szanto, Advokatfirman Vinge KB
Advokatfirman Vinge KB Smålandsgatan 20 Box 1703 111 87 Stockholm Sweden Tel: +46 10 614 30 00 Email: contact@vinge.se Web: vinge.se/en
1. Trends and Overview 1.1 Sanctions Market
invoking grounds such as unseaworthiness, state - lessness, falsified documentation and environmental violations. New rules applicable since 1 July 2025 require proof-of-insurance checks for vessels transit - ing Swedish territorial waters or its economic zone. At the EU level, regulatory activity has intensified markedly. Four further Russia sanctions packages – the 18th, 19th, 20th and 21st – have been adopted during the past 12 months, with measures progres - sively tightening. Key developments include: • reductions to the crude oil price cap; • full transaction prohibitions on certain pipeline operators; • successive port-access and services bans now covering more than 790 shadow fleet vessels; • an outright EU import embargo on Russian LNG; • expanded banking, payment system and crypto- asset restrictions; and • broadened export controls. Additional targeted measures have addressed domes - tic repression, the unlawful transfer of Ukrainian chil - dren, the Russian military-industrial complex, hybrid threats, the shadow fleet ecosystem and third-country circumvention networks. Restrictive measures against Belarus have likewise been reinforced, with expanded controls on trade routes and dual-use goods. Overall, compared with 12 months ago, the sanctions sector is characterised by a considerably more robust legislative framework, faster adoption of EU sanctions packages, and a noticeably more active enforcement posture by Swedish authorities.
The Swedish sanctions landscape has shifted consid - erably over the past year. The most notable legislative development is the new Swedish Sanctions Act imple - menting Directive 2024/1226. The legislation materi - ally strengthens the enforcement framework: • maximum custodial sentences have been raised to three years for standard offences and six years for aggravated or repeated violations; • fines have been removed as a standalone sentenc - ing option; and • new provisions criminalise attempts, instigation and complicity. A misdemeanour offence carrying up to six months’ imprisonment has also been introduced. Agencies are also obliged to refer suspected breaches to the rel - evant enforcement authorities, and forfeiture powers have been extended to cover property not belonging to the offender. Because these rules are recent, their practical application has yet to be tested in the courts. Enforcement activity in Sweden has also become sig - nificantly more prominent. The March 2026 police raid on the Kubal aluminium producer (the country’s sole aluminium producer, under ultimate control of a Rus - sian group), with the arrest of two senior executives for allegedly channelling approximately SEK940 mil - lion in dividends to a sanctioned person, represents a steep change in domestic enforcement visibility. Con - currently, the Swedish Coast Guard has conducted boardings of five suspected shadow fleet vessels,
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