Sanctions 2026

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

4. Delisting Challenges 4.1 Process

into directly applicable regulations, this judgment clar - ifies that the CJEU can provide a preliminary ruling on the interpretation of a measure of general scope in an

act adopted within the CFSP. 3.2 Future Developments

A challenge to an EU sanctions designation can be made before the EU General Court, by lodging an action to annul the listing in the Regulation. Before taking legal action, a request to delist can be submit - ted to the General Secretariat of the EU Council. It is also possible to challenge a listing in the framework of national court proceedings, although this would require the national court to make a reference for a preliminary ruling to the CJEU on the validity of the listing. A United Nations delisting request should be sub - mitted to the United Nations secretariat. Delisting requests regarding the ISIL (Da’esh) and Al-Qaida sanctions list may also be submitted to the United Nations Ombudsman. 4.2 Remedies Successful EU and United Nations delisting challenges can result in either removal from the list or amendment of the designation, depending on the order sought. It is possible to obtain damages for an illegal EU sanctions listing. In a few cases, the CJEU has both considered and upheld claims of damages, and left open the possibility of receiving compensation for both material and non-material damages. Illustra - tively, in Case C-45/15 P, Safa Nicu Sepahan v Coun- cil , the Court of Justice upheld a judgment of the General Court awarding the Iranian plaintiff a sum of EUR50,000 for non-material damages for an improper listing under EU sanctions against Iran. However, the Court of Justice also dismissed the plaintiff’s claim for several million euros worth of damages relating to claimed economic injuries, as the plaintiff had failed to sufficiently demonstrate that these were a result of the listing. For example, while accepting the fact that the plaintiff suffering the termination of a contract with a major supplier was a direct result of the sanctions listing, this did not itself give rise to damages; the plaintiff also needed to demonstrate the impact of the termination on its financial results.

Several developments are anticipated in the near term. The EU anti-money laundering package, adopted in 2024, is set to harmonise the framework for pre - venting the misuse of the financial system for money laundering and terrorist financing across the Union. It comprises the Anti-Money Laundering Regulation (AMLR), the Sixth Anti-Money Laundering Directive (AMLD6) and the Regulation establishing the new EU anti-money laundering agency (AMLAR). The package will enter into force on 10 July 2027, at which point the regulations will start applying and the directive should be transposed into national law. With the new frame - work, the anti-money laundering compliance rules for private actors are transferred to the AMLR, whereas the Sixth AML Directive regulates the organisation of national anti-money laundering authorities. The new AMLR will require “obligated entities” (ie, the institu - tions and actors with extended AML/CFT obligations under EU law) to manage risks for non-implementa - tion and evasion of EU and UN financial sanctions, include such sanctions in their business-wide risk assessment, and integrate sanctions screening into their customer due diligence, beneficial ownership checks and ongoing monitoring. Reforms to Sweden’s military equipment export con - trols are forthcoming. In light of amendments passed in 2026, the Swedish export control framework for military equipment has been aligned with the coun - try’s NATO membership, and the government can now legally grant exemptions from licensing obligations to suppliers of parts to licensed manufacturers. Notably, two key exceptions apply to exports carried out by the Swedish Armed Forces and to exports conducted under EU or NATO programmes. These changes take effect on 1 August 2026 and are expected to enable more streamlined defence industry collaboration with - in the Alliance.

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