Denmark

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1. Does Denmark have a sanctions regime in place?

Yes. UN sanctions are reflected through EU Council Decisions and Regulations which have direct effect in Denmark.

2. Does Denmark implement UN sanctions?

Yes, through EU Council Decisions and Regulations.

3. Does Denmark implement an autonomous sanctions regime?

No. However, the EU may choose to issue sanctions apart from the UN, the so-called autonomous sanctions, against a country.

4. What is the nature of the sanctions regime in Denmark?

The restrictive measures in place include arms embargoes; travel bans against named individuals; import and export controls; and financial sanctions against designated individuals/entities.

5. Does Denmark maintain a list of sanctioned individuals and entities?

Denmark relies on the consolidated list maintained by the EU.

6. Are there any other lists related to sanctions?

No.

7. Does Denmark have a licensing or authorization system in place?

Licences for exporting weapons and defence related material can be obtained from the Minister of Justice. The Ministry of Foreign Affairs is appointed as the co-ordinating authority concerning the implementation of export controls. In addition, applications for authorizations in respect of dual use items can be made to the Danish Business Authority.

8. What are the consequences for a breach of sanctions in Denmark?

The Danish Criminal Code states at section 110c that any person (including corporate entities) who contravenes any provisions or prohibitions that have been provided by law for the fulfilment of the state’s obligations as a member of the UN and the EU shall be liable to a fine and/or, for individuals, a term of imprisonment for a term not exceeding four months, or four years where aggravating circumstances exist. In addition, pursuant to the Danish Statutory Order no 635 of 09 June 2011 (on the application of certain acts of the EU concerning economic relations with third countries, etc) and Danish Executive Order no 712 of 05 July 2019 (on exports of dual use items and technologies) non-compliance with export authorization requirements can also result in a criminal penalty for both individuals and corporate entities. Penalties include a fine and/or, for individuals, a term of imprisonment for a term not exceeding two years.

9. Who are the relevant regulators in Denmark and what are their contact details?

Ministry of Foreign Affairs is the competent authority for Denmark and is appointed as the co-ordinating authority concerning the implementation of export controls:

The Danish Ministry of Foreign Affairs (Udenrigsministeriet) Asiatisk Plads 2DK-1448 København K E: ssp@um.dk

The Danish Business Authority is responsible for provisions on freezing and the administration of international export controls that apply to dual use items:

The Danish Business Authority (Erhvervsstyrelsen) Langelinie Allé 17 DK-2100 Copenhagen O E: eksportkontrol@erst.dk

The relevant authority on ban against import, export, and transportation of e.g. gold, diamonds, petroleum, luxury goods is:

The Danish Custom-house Authorities (Toldstyrelsen) Slet Parkvej 1 8310 Tranbjerg J

E: toldst@toldst.dk

The Ministry of Justice is the competent authority regarding arms embargo: The Ministry of Justice (Justitsministeriet) Slotsholmsgade 10 1216 København K

E: jm@jm.dk

The National Police of Denmark (Rigspolitiet) Polititorvet 14 1780 København V

E: politi@politi.dk

The Ministry of Foreigners and Integration (Udlændinge- og Integrationsministeriet) Slotsholmsgade 10, 1216 København K

E: uim@uim.dk

The Danish Immigration Service (Udlændingestyrelsen) Farimagsgade 51A 4700 Næstved

E: us@us.dk

The following authorities are the relevant authorities regarding travel bans:

For more information on the relevant authorities, please visit https://um.dk/da/udenrigspolitik/folkeretten/sanktioner/ansvarlige-myndigheder/ (only in Danish).

Contributor law firm

Māris Vainovskis Senior Partner E: maris.vainovskis@eversheds-sutherland.lv

Egita Peimane Senior Associate E: egita.peimane@eversheds-sutherland.lv

Līva Lāce Associate E: liva.lace@eversheds-sutherland.lv

Lundgrens Tuborg Havnevej 19 2900 Hellerup Denmark

T: +45 3525 2535 W: https://lundgrens.dk/

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