Sanctions 2026

SWEDEN Law and Practice Contributed by: Anders Leissner, Martin Johansson, Isak Lefvert and Imola Szanto, Advokatfirman Vinge KB

• suspected use of forged documents ( brukande av falsk urkund );

Under Council Regulation 833/2014, express compli - ance obligations have also been codified – for exam - ple, Article 12gb requires exporters of certain sensi - tive goods to identify, assess, mitigate and manage the risks of those goods being diverted to or used in Russia. Furthermore, as many EU sanctions measures also catch indirect actions as well as circumvention, robust and effective compliance programmes are gen - erally integral to preventing breaches of EU sanctions. 2.2.6 Strict Liability Neither the Swedish criminal statutes nor EU sanc - tions regimes operate on a strict liability basis. Only intentional acts and those committed with gross neg - ligence give rise to criminal liability in Sweden. Like - wise, actors breaching EU sanctions can typically not be held liable unless it is proven that they at least had reasonable cause to suspect that their actions were contrary to EU sanctions law. Exemptions from applicable sanctions regulations may be granted upon application to the relevant Swedish competent authority – in most cases either the National Board of Trade or the Inspectorate of Strategic Products. The assessment is based solely on the applicable EU sanctions act. Exceptions vary between different sanctions regimes, and some come as de minimis derogations. For example, regarding deposits from Russia, it may be noted that receiving a deposit amounting to less than EUR100,000 is not prohibited. Examples of recurring grounds for dero - gations include humanitarian aid, international co- 2.3 Licensing 2.3.1 Derogation There is no general licence for the provision of legal services; as with exemptions from sanctions, each individual sanctions regime specifies whether the provision of legal services to designated persons may be exempted. For example, pursuant to Article 4 (1)(b) of Regulation 269/2014 concerning sanc - tions against Russia, and Article 4 (1)(b) of Regulation 359/2011 concerning sanctions against Iran, funds or economic resources intended for the payment of rea - sonable costs in connection with legal services may operation and civil nuclear activities. 2.3.2 Provision of Legal Services

• environmental offences; • breaches of EU sanctions; • uncertain flag-state status; and • deficient seaworthiness.

All boardings except one took place in Swedish ter - ritorial waters off the coast of Skåne; the exception involved a vessel suspected of an environmental offence – an oil discharge – committed in Sweden’s exclusive economic zone, which was subsequently ordered to anchor in territorial waters. The vessels boarded were the Caffa (6 March), Sea Owl I (12 March), Flora 1 (3 April), Hui Yuan (12 April) and Jin Hui (3 May 2026). 2.2.5 Mitigation As regards corporate fines, a company can only be held liable if it failed to take reasonable steps to pre - vent the crime, or if the offence was committed by a person in a leading or supervisory position. This implies that demonstrating robust preventative meas - ures may serve as a defence against a corporate fine. Under Swedish law, these considerations are reflected in the statutory rules on the mitigation and remission of corporate fines. Chapter 36, Section 26 of the Swed - ish Criminal Code provides that a corporate fine may be reduced in cases of more palpable double jeop - ardy, where the company has already been subject to criminal damages, forfeiture or the conviction of, for example, a small business owner. Reduction can also be possible when the company has, to the extent pos - sible, sought to prevent, remedy or limit the harmful effects of the offence, or has voluntarily reported it. Case law confirms that these grounds form part of an overall proportionality assessment, while emphasising that remission is exceptional and fact-specific. More broadly, the EU and Swedish authorities stress that businesses should generally adopt a risk-based approach to sanctions compliance. The European Commission has stated that appropriate due diligence must be calibrated to the specificities of the business and its sanctions risk exposure, encompassing risk assessment, counterparty due diligence and ongoing monitoring.

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