Sweden

Global sanctions guide

Sudan
Switzerland
  1. Does Sweden have a sanctions regime in place?

Yes.

  1. Does Sweden implement UN sanctions?

Yes. Sweden is a member of the European Union, which implements UN sanctions in all member states by way of directly applicable regulations.

  1. Does Sweden implement an autonomous sanctions regime?

Yes.

  1. What is the nature of the sanctions regime in Sweden?

The Swedish Act on Certain International Sanctions (1996:95; the “Sanctions Act”) contains regulations for the implementation of international sanctions. The Sanctions Act allows the government to decree that UN sanctions be implemented. The decree is then submitted to the Parliament (Riksdagen) for approval. Sanctions that can be implemented by such decrees are limited to prohibitions relating to a state under blockade regarding:

  • the residence in Sweden of foreign nationals
  • the import or export of goods, money or other assets
  • manufacture
  • communications
  • granting of credits
  • business activities
  • the circulation of traffic
  • educational and vocational training

Since Sweden entered the EU in 1995, no UN sanctions have been implemented through local legislation. Instead, UN sanctions are implemented jointly through EU Common Positions and EU regulations.

  1. Does Sweden maintain a list of sanctioned individuals and entities?

No. Sweden relies on UN and EU sanctions lists.

  1. Are there any other lists related to sanctions?

No.

  1. Does Sweden have a licensing or authorisation system in place?

Yes. Sweden’s authorisation regime is operated by the National Board of Trade.

  1. What are the consequences for a breach of sanctions in Sweden?

The consequence for a breach of sanctions is criminal liability. Severe cases can lead to imprisonment of up to 4 years (negligent breaches up to 6 months) or a monetary fine (Sec. 8 of the Sanctions Act). There is no liability for minor offences.

Profits from, or property used to assist when committing an offence, may be forfeited (Sec. 11-12 of the Sanctions Act).

  1. Who are the relevant regulators in Sweden and what are their contact details?

The Ministry of Foreign Affairs coordinates Swedish sanctions.

Gustav Adolfs torg
1 103 39 Stockholm
Sweden

T: (+46) 8 405 10 00
F: (+46) 8 723 11 76
E: utrikesdepartementet.registrator@regeringskansliet.se
www.ud.se

Other authorities include:

Financial Supervisory Authority

www.fi.se

The Social Insurance Agency

www.forsakringskassan.se

The National Inspectorate of Strategic Products (ISP)

www.isp.se

National Board of Trade

www.kommers.se

Migration Agency

www.migrationsverket.se

National Police Agency; Rikspolisstyrelsen

www.polisen.se

Swedish Customs

www.tullverket.se

Contributor law firm

Tord Svensson, Eversheds Advokatbyrå AB, Box 14055, Strandvägen 1, SE-104, 40 Stockholm, Sweden