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EU Sanctions Against Russia: What You Need to Know

The European Union has imposed strict sanctions on Russia following its military aggression against Ukraine with Belarusian involvement. The sanctions aim to curb Russian aggression and protect the sovereignty of Ukraine.

Sanctions Compliance

To comply with EU sanctions, companies must screen their clients and business partners against the sanction lists. However, Swedish companies may face additional challenges due to the country’s strict data protection laws. Notably, sanctions screening of individuals against non-legally binding lists, such as the SDN list, requires a permit from the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten) for GDPR reasons.

Enforcement

The Swedish Prosecution Authority is responsible for investigating and prosecuting criminal economic sanctions offenses. Natural persons can be held criminally liable for sanction breaches, while legal persons may face corporate fines.

  • Maximum financial penalties for individuals: SEK 150,000
  • Maximum financial penalties for legal entities: SEK 500,000,000
  • Potential prison sentences: up to two years or four years in cases of gross negligence

Civil Enforcement

There is no specific civil penalty regime for economic sanctions violations. However, breach of sanctions undertakings in contracts may result in damages claims.

Appeals Process

The appeals process follows the same procedure as other criminal convictions in Sweden.

  • Appeal to the District Court within three weeks
  • Review by the Court of Appeal
  • Supreme Court review with a permit

Additional Measures

No proposed unilateral Swedish measures have been announced, although significant changes are expected at the EU level. The EU’s sanctions map provides information on current sanctions.

The main information source about sanctions in Sweden is the government website, which is available in English. The EU’s sanctions map and websites of other relevant authorities also provide important information.

Note: This article has been written by a member of ICLG’s international panel of experts and reviewed by Hollie Parker, our in-house editor. It provides an overview of the EU sanctions against Russia and their implications for Swedish companies.