SWEDEN Trends and Developments Contributed by: Niclas Rockborn, Arijan Kan and Rikard Sundstedt, Gernandt & Danielsson
One relevant consideration is that compliance with international sanctions applicable under European Union or Swedish law may provide a lawful basis for processing personal data, whereas obligations aris - ing solely under foreign law may not. This may limit the circumstances in which a Swedish business may screen individuals against foreign sanctions lists. Another relevant consideration is that Regulation (EU) 2271/96 – commonly referred to as the Block - ing Regulation – prohibits Swedish legal persons from complying, directly or indirectly, with requirements or prohibitions arising from certain extraterritorial United States laws listed in its Annex. Importantly, this does not prohibit the consideration of, or compliance with, United States international sanctions generally. A Swedish legal person must therefore determine whether a decision to refuse, suspend or terminate a transaction or business rela - tionship is based on directly applicable United States law, on genuine and independent commercial con - siderations or solely on an attempt to comply with an extraterritorial United States measure covered by the Blocking Regulation. In the latter case, compliance is prohibited unless authorised by the European Com - mission. Interaction with adjacent regulatory regimes Swedish law differentiates between international sanctions and adjacent but independent regulatory regimes. One example is the export control regime. Legisla - tion on export controls applies independently from that on international sanctions, and imposes sepa - rate requirements concerning classification, licensing, end use and end users. In practice, this means that the same transfer may be subject to both export con - trol requirements and international sanctions require - ments. An export control licence does not over-ride a prohibition under an international sanctions regime, and an authorisation or exemption under an interna - tional sanctions regime does not dispense with any separate export control licence. Another example is the anti-money laundering and counter-terrorist financing regime. Legislation in this
area applies independently from that on international sanctions, and imposes separate requirements con - cerning risk assessments, customer due diligence, ongoing monitoring and suspicious transaction report - ing. In practice, this means that the same customer relationship or transaction may be subject to both anti-money laundering requirements and international sanctions requirements. Compliance with anti-money laundering obligations does not over-ride a prohibition under an international sanctions regime, and compli - ance with international sanctions obligations does not dispense with any separate anti-money laundering or Sweden has no central sanctions authority; responsi - bility is divided among several authorities according to the relevant measure. For example: • the National Board of Trade handles many trade, services, financial restriction and derogation mat - ters; • the Inspectorate of Strategic Products is responsi - ble for military equipment and dual-use items; • the Swedish Financial Supervisory Authority per - forms certain reporting, authorisation, freezing and supervisory functions; and • Swedish Customs enforces import and export restrictions at the border. counter-terrorist financing requirement. Fragmented Responsibilities But Closer Co-Ordination Suspected sanctions offences are investigated by the competent law enforcement authority – principally the Swedish Police Authority or Swedish Customs, with the Swedish Security Service involved in matters fall - ing within its national security remit. This fragmentation has been identified as a weakness in the Swedish enforcement framework. To improve co-ordination, the Sanctions Co-ordination Council, led by the Swedish Police Authority, was placed on a permanent footing in July 2026. It does not replace the participating authorities nor create a single point of contact, and businesses must still identify the compe - tent authority for each specific application, notification or inquiry.
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