Sanctions 2025

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

• Crude oil or natural gas (import): Check Article 3a of Council Decision 2010/413/CFSP of 26 July 2010. • Gold, diamonds, etc (import): Check Article 4c of Council Decision 2010/413/CFSP of 26 July 2010. • Military goods and technology (export): Check Annex II of Council Regulation (EU) 2023/1529 of 20 July 2023 and Annexes III and VIIA of Council Regulation (EU) No 267/2012 of 23 March 2012. • Raw materials (gold, diamonds, aluminium, steel, graphite) (export): Check Articles 4e and 26f of Council Decision 2010/413/CFSP of 26 July 2010 and Article 15 a of Council Regulation (EU) No 267/2012 of 23 March 2012. • Telecommunications equipment (export): Check Annex IV of Council Regulation (EU) No 359/2011 of 12 April 2011. North Korea For North Korea, the restrictions are as follows. • Military goods, technology, arms and related technology (import and export): Check Annex II of Council Regulation (EU) 2017/1509 of 30 August 2017. • Aviation fuel (export): Check Annex III of Council Regulation (EU) 2017/1509 of 30 August 2017. • Gold, titanium ore, vanadium ore and rare-earth minerals (import): Check Annex IV of Council Regu - lation (EU) 2017/1509 of 30 August 2017. • Coal, iron and iron ore (import): Check Annex V of Council Regulation (EU) 2017/1509 of 30 August 2017. • Petroleum products (import): Check Annex VI of Council Regulation (EU) 2017/1509 of 30 August 2017. • Copper, nickel, silver and zinc (import): Check Annex VII of Council Regulation (EU) 2017/1509 of 30 August 2017. Sudan For Sudan, restrictions apply to military goods and technology (export): check Article 1 of Council Deci - sion 2014/450/CFSP of 10 July 2014. Libya For Libya, the restrictions are as follows.

• Military goods, arms and related equipment used for internal repression (export): Check Article 1 of Council Decision (CFSP) 2015/1333 of 31 July 2015. • Goods that could be used for the smuggling of migrants and trafficking in human beings (export): Check Annex VII of Council Regulation No 36 of 18 January 2012. • Military goods, arms and related equipment used for internal repression (import): Check Article 3 of Council Decision (CFSP) 2015/1333 of 31 July 2015 and Annex IA of Council Regulation No 36 of 18 January 2012. • Crude oil and petroleum products (import): Check Article 6 of Council Regulation (EU) No 36 of 18 January 2012. Venezuela For Venezuela, restrictions apply to military goods, arms, equipment used for internal repression and related goods (export): check Articles 1 and 3 of Council Decision (CFSP) 2017/2074 of 13 November 2017. Iraq All proceeds from export sales of petroleum, petro - leum products and natural gas from Iraq, as listed in Annex I of Council Regulation (EC) No 1210/2003, shall – as of 22 May 2003 – be deposited into the Development Fund for Iraq under the conditions set out in United Nations Security Council (UNSC) Reso - lution 1483 (2003), particularly paragraphs 20 and 21 thereof. Any export from Iraq or dealings in Iraqi cultural prop - erty – and other items of archaeological, historical, cultural, rare scientific and religious importance – shall be prohibited: Check Annex II of Council Regulation (EC) No 1210/2003 of 7 July 2003. Specifically relating to the import of timber, EU com - panies also need to be aware of the EU Timber Regu - lation (Regulation (EU) No 995/2010 of 20 October 2010), which sets out due diligence procedures to be undertaken by companies involved in the trading of timber in the EU.

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