SWEDEN Law and Practice Contributed by: Annika Blomqvist, Sanna Frånlund, Henrik Lindstrand and Viktor Eriksson, Advokatfirman Cederquist
was committed by a person in a senior position or with particular responsibility for supervision or control. The corporate fine is based on a sanction value of between SEK5,000 and SEK10 million. For larger companies, the fine may be increased by reference to the company’s financial position and may amount to a maximum of SEK500 million. A corporate fine may be reduced where the company has taken reasonable steps to prevent, remedy or limit the harmful effects of the offence, or has voluntarily reported it. 4.8 Recent Enforcement Actions and Developments The Swedish International Sanctions Act has only been in force since June 2025, and there is there - fore yet limited case law concerning its application, although there have been several preliminary investi - gations for sanctions violations. Although the Swedish Sanctions Co-Ordination Coun - cil was established in 2024, a regulation formalising its role and functions came into force in 2026. Given the increased focus on sanctions circumventions, more developments are expected in the coming year. 5. National Security Regulation 5.1 National Security Legislation Applicable to the Defence Sector The principal legislation governing national security in the defence sector in Sweden comprises the fol - lowing. • The Protective Security Act (2018:585) and the Pro - tective Security Ordinance (2021:955) applicable to public and private entities conducting security-sen - sitive activities. The Swedish Security Service and the Swedish Armed Forces act as co-ordinating authorities for the designated authorities. • The Military Equipment Act (1992:1300) and the Military Equipment Ordinance (1992:1303) regulate manufacturing, supply, exportation and brokering of military equipment. The regulations also apply to agreements concerning manufacturing rights and technical assistance concerning military equip - ment. Supervision and relevant authorisation are
exercised by ISP. The government may determine certain matters of principle or particular impor - tance. • The Strategic Products Acts (2025:952) and the Strategic Products Ordinance (2026:6) together with the EU Dual-Use Regulation apply to exports, brokering, transit and technical assistance involv - ing dual-use and other strategically sensitive prod - ucts. ISP is the main supervisory authority. The Swedish Radiation Safety Authority may review matters concerning nuclear materials and related products, while Swedish Customs is responsible for relevant border control. • The Screening of Foreign Direct Investments Act (2023:560) (the “FDI Act”) and the Ordinance (2023:624) on Screening of Foreign Direct Invest - ments establish mandatory and suspensory screening of investments in protected activities. ISP is the designated screening and supervisory body. • The Public Access to Information and Secrecy Act (2009:400) and Chapter 19 of the Swedish Criminal Code (1962:700) concerning protection of informa - tion relating to national defence and security, and establishing criminal liability for offences including espionage and unauthorised dealings with classi - fied information. 5.2 Security Vetting and Clearance Requirements Individuals participating in security-sensitive activities under the Protective Security Act must undergo secu - rity vetting before access is granted to the relevant activity. The scope of the vetting must be proportion - ate to the individual’s role and ordinarily includes basic investigation. Individuals holding positions classified within security classes require register checks and, for classes 1 and 2, a special personal investigation. Positions are assigned to classes based on the level of sensitive information accessible through the position in relation to the potential harm to national security if the information is disclosed. The Swedish Security Service conducts the register checks but does not grant security clearance. The relevant employer or operator is responsible for the overall suitability assessment and the final decision on access. The vetting is a continuously ongoing
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