1. Does Sweden have a sanctions regime in place?


2. Does Sweden implement UN sanctions?


3. Does Sweden implement an autonomous sanctions regime?

The sanctions that apply in Sweden are decided by the UN or the EU. Sweden does not have its own, nationally decided sanctions. Sweden does however have its own regulations in respect of export of military equipment and dual-use products; it is illegal to export military equipment and dual use products without a permit.

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

International Sanctions issued by the EU are directly applicable and have direct effect in Sweden as a member state.

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.

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

Not a separate list – only EU and UN lists.

6. Are there any other lists related to sanctions?

No (see above).

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

Yes. With respect to international trade, this is operated by the National Board of Trade (Sw. Kommerskollegium).

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

Criminal liability, severe cases with an imprisonment of up to four years and negligent breaches up to six months or monetary fine (Sec. 8 of the Sanctions Act). There is no liability for minor offences.

Breach against an international sanction can lead to that at corporate fine is issued against the corporation.

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

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

The Ministry of Foreign Affairs coordinates Swedish sanctions. W: 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

Michael Nyman,


Mathilda Andersson,


Eversheds Advokatbyrå AB,

Box 14055,

Strandvägen 1,


40 Stockholm,


T: (+46) 8 545 322 00


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