Norway

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1. Does Norway have a sanctions regime in place?

Yes, Norway’s export control regime must be complied with by any individual or entity domiciled or resident in Norway.

2. Does Norway implement UN sanctions?

Yes.

3. Does Norway implement an autonomous sanctions regime?

Neither EU Regulations nor UN Resolutions have direct effect in Norway and must be implemented in Norway by local legislation. Norway is obligated under international law to implement UNSC binding resolutions and after an assessment Norway can endorse EU Regulations. Thus, when sanctions or embargoes are set by the UN or the EU, Norway must enact implementing regulations. There are already in place relevant acts empowering the government to make such regulations. Export restriction regimes and sanctions are implemented by Norway individually for each country to which restrictions apply. The most frequently applied measures under Norwegian legislation are: arms embargoes and non-military measures, ie blockage of economical or other connections to third party states, organisations and representative individuals.

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

There are requirements for export licenses for defence-related items, and breach of this and trading in breach of sanctions are criminal offenses. Seizure of goods is always a possibility based on breach of relevant acts and regulations being criminal offenses. The export control regime is managed by the Norwegian Ministry of Foreign Affairs. It applies to defence equipment as well as civilian goods, technology and services with potential military application as described in lists that are negotiated within the multilateral export control cooperation that Norway participates in.

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

Norway does not maintain an independent list of sanctioned individuals and entities; it largely adopts the list contained in the corresponding UNSC Resolutions and/or EU Regulations which are implemented as described under question 3. All such lists are appendices to the relevant enforcing regulations.

6. Are there any other lists related to sanctions?

The Norwegian Ministry of Foreign Affairs has developed two lists related to export control which describe: (i) defence equipment and (ii) civilian goods, technology and services with potential military application. The lists are negotiated within the multilateral export control cooperation that Norway participates in. The Ministry also has on its website updated lists of countries subject to sanctions and weapons embargo.

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

For export control under the defence-related regime the Norwegian Ministry of Foreign Affairs can grant individual licences (to one exporter for one delivery/shipment to an identified consignee), or general licences (to one exporter for unlimited shipments within a given period, usually one year, of a specified good to any consignee in one or more countries). All applications must since 2015 be made electronically.

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

The maximum penalty for a violation of the Act on Control of the Export of Strategic Goods, Services and Technology, etc., is fines and/or imprisonment of up to five years. For breach of the Sanctions Act the maximum imprisonment is three years. As breach of relevant acts and regulations are criminal offences, seizure of goods and material is always a possibility. Other consequences may apply under specific legislation such as the Anti-money Laundering Act. Travelling restrictions may be issued by the government under the Immigration Act.

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

The section for Export Control within the Norwegian Ministry of Foreign Affairs is responsible for the national implementation and administration of export control, both in terms of policy frameworks, legislation and processing of applications for licences. The ministry is also responsible for the sanction regime.

Norwegian Ministry of Foreign Affairs Postboks 8114 Dep. N-0032 Oslo T: (+47) 23 95 06 50 E: post@mfa.no and lisens@mfa.no

Finanstilsynet is responsible for monitoring the compliance of the requirements by the various reporting entities within the financial sector and for auditors and real estate agents: Finanstilsynet (the Norwegian Financial Supervisory Authority) Revierstredet 3 0151 Oslo T: (+47) 22 93 98 00 E: post@finanstilsynet.no

Politiets sikkerhetstjeneste (PST) (the Norwegian Police Security Service) is responsible for investigations into offences related to terrorist financing, with Økokrim (the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime) being responsible for anti-money laundering offences.

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Peter L. Brechan Senior Counsel

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