SWEDEN Law and Practice Contributed by: Annika Blomqvist, Sanna Frånlund, Henrik Lindstrand and Viktor Eriksson, Advokatfirman Cederquist
4.5 Extraterritorial Sanctions and Secondary Sanctions Risk The international sanctions applicable in Sweden are those adopted by the EU or the UN. Sweden does not recognise or give effect to extraterritorial sanctions imposed by third countries. Such sanctions may nev - ertheless create legal, financial and commercial risks for Swedish entities. 4.6 Sanctions Compliance Programmes A sanctions compliance programme should be risk- based and tailored to each entity’s operations and risk exposure. Factors relevant to evaluating the risk expo - sure could be supply chains, customers and end-user identification, type of products or services, transport routes and payment flows. Based on the risks identi - fied, appropriate and proportionate measures should be implemented. The risk exposure and measures should be regularly reviewed. There should be clear allocation of responsibilities with oversight of senior management. The sanctions programme should include regular training of staff, routines for monitoring, as well as reporting and esca - lating mechanisms. 4.7 Enforcement, Penalties and Voluntary Disclosure Under the Swedish Act on International Sanctions (2025:327) an intentional or grossly negligent sanc - tions offence may result in imprisonment for up to three years. A minor offence may result in a fine or imprisonment for up to six months. An intentional aggravated or repeated offence may result in impris - onment for between two and six years. When determining whether an offence is aggravat - ed, particular consideration is given to whether the offence concerns a very significant value, involves military equipment or dual-use items, or is otherwise of a particularly dangerous nature. A corporate fine under the Swedish Criminal Code may be imposed on legal entities where an offence has been committed in its business and the company has failed to take the measures that could have been reasonably required to prevent it, or where the offence
The Swedish Sanctions Co-Ordination Council was established in 2024 to strengthen co-operation among the authorities responsible for preventing, detecting, investigating and prosecuting sanctions violations. 4.2 Arms Embargoes Sweden implements arms embargoes imposed by the UN Security Council. In addition, the EU has autono - mously imposed arms embargoes and, in relation to certain countries, prohibitions concerning equipment that may be used for internal repression. ISP is the competent Swedish authority for matters relating to such embargoes. 4.3 Screening and Due Diligence Requirements Defence sector participants must comply with appli - cable sanctions and should implement appropriate, risk-based measures to avoid dealing with sanctioned parties. Where applicable sanctions require screening of counterparties and business partners, such require - ments should be complied with. There is no general due diligence requirement appli - cable to all situations. Generally, economic operators should continuously identify, evaluate and understand the risks of circumventions in their own operations and implement appropriate measures to reduce the risk of participating in or being used to circumvent applicable sanctions. The scope and frequency of the due diligence measures should be determined based on the risks associated with each company’s opera - tions. 4.4 Licences, Derogations and Exceptions Exceptions from applicable sanctions are available only where expressly provided in the relevant sanc - tion’s regulation. The Swedish government will appoint the competent national authority to process applica - tions for an exception. For example, ISP generally handles matters concerning dual-use items, equip - ment that may be used for internal repression and arms embargoes, while the National Board of Trade reviews most other exemption applications concern - ing legal entities.
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