Sanctions 2025

DENMARK Law and Practice Contributed by: Anders Amstrup Fournais and Sarah Bisgaard Møller, Hafnia Law Firm LLP

4.3 Timing How long it might take to obtain delisting depends on the time it takes for the EU litigation to be completed, including any potential appeal to the CJEU. Previ - ous cases show the delisting procedure has taken between 4 and 12 months from the application to the CJEU decision, but it may take longer depending on the circumstances of the case. 5. Trade and Export Restrictions 5.1 Services The EU has adopted import and export restrictions against Belarus, Iran, Iraq, Libya, North Korea, Russia, the Russian-controlled oblasts of Ukraine (Crimea and Sevastopol, Donetsk, Kherson, Luhansk and Zapor - izjzja), Sudan, Syria and Venezuela. A non-exhaustive summary is set out in the following (written jointly for goods and services; further information is available at EUR-Lex). Russia For Russia, the restrictions are as follows. • Dual-use goods and technology (export): Check Annex I of Regulation (EU) 2021/821 of 20 May 2021. • Military goods and technology (export): Check Annex VII of Council Regulation (EU) No 833/2014 of 31 July 2014. • Firearms and ammunition (export): Check Annex I of Regulation (EU) No 258/2012 of 14 March 2012 and Annex XXXV of Council Regulation (EU) No 833/2014 of 31 July 2014. • Items for use in the oil and gas industry (export): Check Annex II of Council Regulation (EU) No 833/2014 of 31 July 2014. See also Annex X of Council Regulation (EU) No 833/2014 of 31 July 2014. • Goods and technology suited for use in aviation or the space industry (export): Check Annex XI of Council Regulation (EU) No 833/2014 of 31 July 2014. • Maritime navigation goods and technology (export): Check Annex XVI of Council Regulation (EU) No 833/2014 of 31 July 2014.

The deadline for implementation was May 2025, and thus has passed. Instead of turning the Harmonisation Directive into Danish law, the Danish legislator has proposed a bill that ramps up criminal enforcement for sanctions violations by extending the time limits for bringing criminal proceedings, and by extending the maximum prison sentence to five years or up to eight years in case of intentional breaches under aggravat - ing circumstances.

4. Delisting Challenges 4.1 Process

Denmark does not designate persons or entities inde - pendently of the EU. Designations under EU sanctions are made by the EU’s executive body, the European Council (EC). Any requests for delisting must therefore be served within the EU. There is a procedure for the EC to consider a request for delisting, in which it hears the member state(s) that proposed the listing, as well as all other member states. A request for de-listing can be made to the EC but proceedings must be commenced before the General Court within two months of the publication of the listing. The judgment may be appealed to the Court of Justice of the European Union (CJEU). The CJEU has decided that a third state can also qualify as a “legal person” directly affected by EU sanctions, and can bring an action for annulment even though the EU has no reciprocal right before the courts of third States (Venezuela v Council, C-872/19 P). 4.2 Remedies In the event of a successful delisting challenge, the relevant person or entity will be removed from the sanctions list. This means the person or entity’s assets will be unfrozen – ie, bank accounts can be used again. There is no legal basis for claiming dam - ages, but the person or entity being delisted can have its costs related to the delisting challenge paid by the EC if the delisting challenge is successful.

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