SWEDEN Law and Practice Contributed by: Anders Leissner, Martin Johansson, Isak Lefvert and Imola Szanto, Advokatfirman Vinge KB
Criminal enforcement is the responsibility of the Pros - ecution Authority’s National Security Unit ( Riksen- heten för säkerhetsmål ). Criminal investigations are carried out by the Police Authority ( Polismyndigheten ), together with the Swedish Security Service ( Säkerhet- spolisen ). Legal persons that commit a sanctions breach and are subject to regulatory oversight may face regula - tory enforcement action by the supervisory authority competent under the applicable legislation. 2.2.2 Breaching Sanctions In many cases, a breach of sanctions will constitute a criminal offence in Sweden. Only intentional acts, or acts committed with gross negligence, give rise to criminal liability; the standard of proof is “beyond reasonable doubt”. Liability also extends to instiga - tion, aiding and attempted commission of a sanctions offence. Under the new Swedish Sanctions Act, an ordinary sanctions offence carries a custodial sentence of up to three years. Gross or repeated offences are pun - ishable by two to six years’ imprisonment. A separate misdemeanour category exists, carrying a maximum penalty of six months’ imprisonment, where prosecu - tion is deemed to be in the public interest. In practice, petty offences will attract only fines. For individuals, the maximum fine for a single sanctions offence is SEK150,000, rising to SEK200,000 where multiple offences are involved. No financial penalty is imposed where the offence warrants a prison sentence. Under the new penalty regime, prison sentences in less serious cases may be conditional or partly con - ditional, and a conditional sentence can be combined with a duty to pay fines, community service obliga - tions, or surveillance. Property connected to the offence may also be subject to forfeiture, even where it does not belong to the wrongdoer. Regarding legal entities, Swedish law does not rec - ognise corporate criminal liability – only natural per - sons can commit criminal offences. However, where a crime has been committed within the scope of a company’s operations, the company may be ordered to pay a corporate fine under Chapter 36, Section 23
of the Swedish Criminal Code. A corporate fine may be imposed if the company did not take reasonable steps to prevent the offence, or if the offender was someone in a leading or supervisory role. For larger legal entities, corporate fine can reach a maximum of SEK500 million for gross sanctions offences (see Chapter 36, Sections 24 and 25). For other violations, or for companies that do not qualify as “larger legal entities”, the standard range is SEK5,000 to SEK10 million, depending on the gravity of the offence. It should be noted that, in Sweden, criminal sentenc - ing is shaped predominantly by case law. Given that case law on sanctions violations remains extremely limited, it is challenging to assess with any precision the penalties likely to be imposed for such breaches – including whether custodial sentences will gener - ally tend towards unconditional or conditional impris - onment under the new penalty framework. When enacting the Swedish Sanctions Act, the legislature expressly acknowledged that it would fall to the courts to determine whether sanctions violations should ordi - As there is no civil enforcement regime (see 2.2.1 Enforcement Responsibilities ), there is no enforce - ment action to report. 2.2.4 Criminal Enforcement Action On 26 March 2026, a law enforcement tactical unit executed a raid on the Russian-owned Kubal alu - minium smelting facility in Sundsvall. Two individuals holding senior management positions are suspected of aggravated sanctions violations; one of the sus - pects serves as the company’s CEO. The full basis for the criminal suspicions has not been disclosed and the criminal investigation is ongoing. Under applicable law, an individual convicted of aggravated breach of sanctions legislation faces a term of imprisonment of no less than two years and no more than six years. Since early 2026, the Swedish Coast Guard has boarded five vessels suspected of links to the so- called shadow fleet. The legal bases for these inter - ventions include: narily carry a custodial sentence. 2.2.3 Civil Enforcement Action
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