Finland

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1. Does Finland have a sanctions regime in place?

Yes. EU Council regulations are directly applicable.

2. Does Finland implement UN sanctions?

Yes. All sanctions imposed by the UN Security Council are implemented by EU-level legislation.

3. Does Finland implement an autonomous sanctions regime?

No.

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

Finland implements the EU sanctions regimes, restrictive measures include arms embargoes, other export and import restrictions, asset freezes, other targeted restrictive economic measures (sectoral sanctions), restrictions on traffic and transport, restrictions on admission.

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

No. Finland relies on UN and EU sanctions lists.

6. Are there any other lists related to sanctions?

No.

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

Yes. Goods and services covered by a sanctions regime require export and/or transfer authorizations to the extent such authorizations can be granted. The Ministry for Foreign Affairs authorizes the transfer of funds where sanctions apply. Applications for fund transfer authorizations are generally lodged by the exporting party’s Financial Intermediary.

The Ministry for Foreign Affairs is also the licensing authority of dual-use items in Finland and responsible for the administration of the EU export control.

The Ministry of Defence is the licensing authority of defence materiel exports.

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

The consequences for a breach or attempted breach of sanctions, including UN and EU sanctions, are set out in Chapter 46 of the Finnish Criminal Code (offenses connected to import and export). They are:

  • for a petty regulation offense, a fine,
  • for a regulation offense, a fine or imprisonment for up to two years; and
  • for an aggravated regulation offense, imprisonment for between four months and four years.

The applicable penalties are directed at those individuals who are considered having committed the relevant offense or participated in the decision making leading to such offense. The provisions on corporate criminal liability apply to regulation offenses. Corporate criminal liability may entail a corporate fine ranging from EUR 850 to EUR 850,000.

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

The Ministry for Foreign Affairs is responsible for administering UN and EU sanctions in Finland. Ministry of Foreign Affairs PO Box 176 FI-00023 Government Finland https://um.fi/ministry Contact details: https://um.fi/contact-information

Ministry’s website on international sanctions: https://um.fi/international-sanctions

Contributor law firm

Anu Matilla, Partner

Eversheds Asianajotoimisto Oy,

Fabianinkatu 29 B,

Helsinki,

00100,

Finland

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