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Sanctions Busting: Norway’s Secret Path to Success

In a bold move, Norway is taking a different approach to economic sanctions by quietly allowing certain activities that would normally be prohibited. The country’s regulators have created a system that allows for exemptions from the usual sanctions regime, providing a window of opportunity for those looking to circumvent restrictions.

Exemptions Galore

The Norwegian Ministry of Foreign Affairs (MFA) has been granted significant discretion to grant exemptions from sanctions regulations in special cases where the regulation has an unintended effect. This could include situations where the exemption does not conflict with Norway’s international law obligations or the motivations behind the measures.

Reporting Requirements

• Credit institutions are required to report on deposits exceeding EUR 100,000 held by Russian persons or entities.
• Exporters and other persons assisting in the trade of certain goods and services must report certain information regarding their transactions to the MFA. This includes details such as:
  • Type of goods
  • Quantity
  • Value
  • Transfer date
  • Supplier and consignee information
  • End-use certification
  • Payment details

Criminal Penalties

• Violations of Norway’s economic sanctions laws and regulations are punishable by criminal penalties, including fines and imprisonment.
• However, there is no civil enforcement institute in Norway, and the MFA may revoke, suspend or restrict an already issued export licence if it is abused or breached.

Civil Consequences

• A breach of the economic sanctions regulations can still have significant consequences. The MFA may issue daily fines for non-compliance with information requirements.
• A court of law may seize goods, funds or securities used in violation of the UN sanctions regulations.

Appeal Process

• If you are found guilty of violating Norway’s economic sanctions laws and regulations, you can appeal the decision to a higher court. The Supreme Court has the final say on matters of criminal guilt.

Statute of Limitations

• The statute of limitations for criminal enforcement of economic sanctions violations depends on the maximum statutory penalty prescribed.
• In general, the limitation period is five years when the maximum statutory penalty is imprisonment for three years.

By taking a more relaxed approach to economic sanctions, Norway is creating opportunities for businesses and individuals to operate in ways that would normally be prohibited. While this may raise concerns about the integrity of the sanctions regime, it also demonstrates the country’s commitment to flexibility and cooperation.

How to Access Sanctions-Related Materials

• The Norwegian Government has prepared a list of relevant sanction laws and regulations, which are publicly available on their website.
• However, these materials may not be easily accessible in English, requiring some effort to translate or obtain them from other sources.