Sanctions 2026

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

3. Recent and Future Legal Developments 3.1 Significant Court Decisions or Legal Developments As mentioned in 1.1 Sanctions Market and 1.2 Key Trends , Sweden has seen significant developments in recent years, but there have been no court decisions directly related to sanctions in the past three years. On the EU level, three important case law develop - ments can be mentioned. Aside from the notion of “control” cases, as discussed in 1.2 Key Trends , the CJEU judgments in Cases C-109/23, Jemerak , and C-351/22, Neves 77 Solutions , are of particular inter - est. In the Jemerak case, the CJEU was asked whether German notary and translation services in relation to an immovable property sale were covered by the pro - hibition to provide legal advisory services to a Russian legal person under Regulation 833/2014. The Court answered the question in the negative, emphasising that the independent functions of a notary in the Ger - man legal system distinguished such notary services from the services that a legal counsel would perform. The notary services in question would thus not fall under the EU sanctions on the provision of legal ser - vices, nor would related translation services. In the Neves 77 Solutions case, the CJEU confirmed its jurisdiction to interpret EU Council sanction deci - sions directly in cases not covered by EU regulations implementing the sanctions. In the case at hand, a Romanian company had brokered a transaction with Russian military radio equipment in violation of a pro - hibition in a 2014 Council decision adopted in the context of the Common Foreign and Security Policy (CFSP), which at the time had not yet been imple - mented in Regulation 833/2014; however, the prohi - bition had been enshrined in Romanian law. In the national proceedings, the Court was asked to interpret the decision. While several parties claimed that the Court lacked jurisdiction to interpret the decision as the Council had failed to implement it into a regulation, the Court held that this failure did not impair its juris - diction to interpret the underlying decision. Although Council decisions are normally implemented directly

be released. No amendments to these two provisions have been made in the past 12 months. 2.4 Reporting There is no general, blanket reporting obligation under Swedish sanctions law, although several specific duties exist. • First, a licence granted by a competent author - ity (see below) may be made conditional upon the fulfilment of particular reporting requirements. • Second, any party holding frozen funds – such as a financial institution – is obliged to notify the Finan - cial Supervisory Authority ( Finansinspektionen ) of that holding. • Third, and notably, the Swedish Sanctions Act introduced a new institutional reporting duty. A number of Swedish government agencies are now required to report any suspicion that a sanctions breach has occurred under the Act to the Police Authority ( Polismyndigheten ) or the Prosecution Authority ( Åklagarmyndigheten ). • Fourth, at the EU level, the sanctions regulations themselves typically contain a general – albeit broadly worded – obligation requiring all natu - ral and legal persons, entities and bodies falling within the scope of those regulations to report any information that would “facilitate compliance” with financial sanctions. Sanctions-related personal data processing is also subject to recent regulatory developments. In Novem - ber 2024, a new ordinance issued by the Swedish Authority for Privacy Protection ( Integritetsskyddsmyn- digheten ) came into force. This ordinance removes the prior requirement for entities in the financial, security and defence industries to seek advance authorisa - tion from the supervisory authority when conducting screenings against non-EU sanctions lists, so long as the data processing is governed by the applicable sectoral rules. For organisations active in other fields, a case-by-case GDPR assessment may still be nec - essary.

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