SWEDEN Trends and Developments Contributed by: Niclas Rockborn, Arijan Kan and Rikard Sundstedt, Gernandt & Danielsson
liability and corporate fines; see Materially Strength- ened Enforcement Regime below for more detail. Compliance framework – developing market practice Structured sanctions compliance frameworks can - not yet be regarded as standard practice across all segments of the Swedish market. It is nevertheless becoming more common, particularly among estab - lished businesses, exporters and companies with international operations or supply chains. Developing best practice, which has been codified by the European Banking Authority’s non-mandato - ry guidelines applicable as of 30 December 2025, includes a documented risk assessment, clear alloca - tion of responsibilities, and practical controls tailored to the company’s operations and sanctions exposure. The risk assessment should identify where sanc - tions violations may arise in light of the company’s operations, markets, products, customers, suppliers, payment flows, distribution channels and corporate structure. Higher risk arrangements should receive particular attention, including those involving distribu - tors, agents, freight forwarders and foreign subsidi - aries. The assessment should be updated following material changes to the business or its sanctions exposure. Responsibility for sanctions compliance should be clearly allocated between management and relevant operational functions. Internal procedures should specify when transactions may be approved, esca - lated, suspended or rejected, and training should be directed at functions exposed to sanctions risk, including sales, procurement, finance and logistics. Screening, due diligence and other control measures should be proportionate to the company’s sanctions exposure, and may extend beyond the direct counter - party to owners, controlling persons, intermediaries, banks, consignees and end users. Higher risk trans - actions may require verification of ownership records, product classifications, end use information, shipping documents, payment flows and commercial rationale. Businesses with complex supply chains should also consider re-export restrictions, downstream obliga -
ed with the Russian military industrial sector. Higher risk products and supply chains may therefore require enhanced counterparty, end use and transaction due diligence. Circumvention is likely to remain a central Swedish enforcement priority. Further investigations and pros - ecutions can be expected as the authorities increase their focus on indirect exports, procurement networks and the use of third-country intermediaries; see Mate- rially Strengthened Enforcement Regime below for more detail. Governance and Compliance Gain Importance Compliance is mandatory, internal measures voluntary Swedish sanctions law is prohibition-based rather than process-prescriptive. Businesses must comply with the applicable restrictions, but are not gener - ally required to maintain specific screening, due dili - gence or internal control arrangements. Unless such requirements arise under sector-specific regulation, the choice of compliance measures is therefore for - mally voluntary. This distinction is becoming less significant in prac - tice. The broader criminal law framework introduced in 2025 has increased the importance of businesses being able to identify and address international sanc - tions risks. The board of directors is ultimately responsible The board of directors is ultimately responsible for ensuring that the company conducts its business in accordance with the applicable laws and regulations, including international sanctions. The board should therefore ensure that responsibilities are allocated and that proportionate procedures and controls are in place in this area. Documented compliance arrangements may be rele - vant both when assessing whether an individual acted with gross negligence and when determining whether the company took the measures that could reasonably have been required to prevent an offence. Appropriate controls may therefore reduce both the risk of a viola - tion and the resulting exposure to individual criminal
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