Sanctions 2026

SWEDEN Trends and Developments Contributed by: Niclas Rockborn, Arijan Kan and Rikard Sundstedt, Gernandt & Danielsson

Gernandt & Danielsson Hamngatan 2 Box 5747 SE-114 87, Stockholm Sweden

Tel: +46 8 670 66 00 Email: info@gda.se Web: www.gda.se

Overview and Current Trends Sweden’s international sanctions framework is under - going its most significant change in decades. The international sanctions applicable in Sweden are prin - cipally those adopted by the European Union, includ - ing measures implementing sanctions adopted by the United Nations Security Council. The International Sanctions Act (SFS 2025:327), which entered into force in June 2025, introduced a broader and more stringent criminal law framework for sanc - tions violations. This was followed in July 2026 by the establishment on a permanent footing of the Sanc - tions Co-ordination Council, bringing together the principal Swedish authorities involved in sanctions implementation and enforcement. These developments reflect a broader shift in Swe - den’s approach to international sanctions: from a regime centred primarily on self-driven compliance to one with a more pronounced enforcement orientation. For Swedish businesses, international sanctions are consequently becoming a question of criminal expo - sure, corporate governance and transaction risk. The Legal Framework: Broader Criminal Enforcement The International Sanctions Act The International Sanctions Act (SFS 2025:327) entered into force in June 2025 and is the core legisla - tion governing international sanctions under Swedish law. It sets out which sanctions apply in Sweden, and provides for their criminal law enforcement.

More specifically, the provisions of the Act are struc - tured as blanket offences. Criminal liability arises from breaches of prohibitions, obligations or restrictions adopted by the European Union under the Common Foreign and Security Policy or the United Nations Security Council; see Restrictions of Practical Impor- tance below for more detail. Importantly, Swedish sanctions legislation is primarily prohibition-based. It designates conduct as prohibited or restricted, but does not prescribe specific control measures that individuals and businesses must pro - actively perform in order to be compliant. There are therefore no statutory requirements under Swedish law to conduct sanctions screening, perform sanc - tions-specific due diligence or maintain particular poli - cies, procedures or internal controls, although such controls are often justified as a practical approach to ensuring compliance; see Governance and Compli- ance Gain Importance below for more detail. European Union sanctions International sanctions within the European Union are normally introduced through a decision under the Common Foreign and Security Policy; where Euro - pean Union-level implementation is required, they are given effect through directly applicable Council regulations. Measures requiring action by individual member states, such as certain arms embargoes or admission restrictions, are implemented nationally. The substantive restrictions applicable to Swedish businesses are therefore determined principally at European Union level.

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