Finland and Sweden implement EU directive on sanctions

In 2025, Sweden and Finland adopted new laws introducing stricter criminal liability for violations of international sanctions. Both documents are aimed at implementing EU Directive 2024/1226 on the criminalization of sanctions evasion and establish a unified approach to holding both individuals and legal entities accountable.

In Sweden, the relevant law will enter into force on June 10. It provides not only for stricter penalties but also for the criminalization of even minor violations. For the first time in Swedish legislation, separate offenses are introduced: violation of sanctions, sanction offense, gross sanction offense, and repeated sanction offense. In addition, criminal liability will be extended to attempts and aiding and abetting, and a number of state institutions will be required to report suspected violations of sanctions legislation.

In Finland, new legislation will come into force on May 20. The key changes concern the introduction of new sanctionable offenses into the Criminal Code and the revision of corporate liability. From now on, violations of sanctions, including those with aggravating circumstances or due to negligence, will be punishable under criminal law. Administrative liability for such acts will be abolished.

The new approach to corporate fines deserves special attention. Whereas previously the maximum fine for legal entities was €850,000, it can now reach 5% of a company's annual turnover for sanctions violations, but no less than €850,000 and no more than €40 million. This exception applies only to sanctions offenses and is introduced in accordance with the requirements of the EU Directive.

The changes in Sweden and Finland are part of a Europe-wide process of harmonizing sanctions policy. They are intended to ensure the same level of liability in all EU Member States and make circumvention of sanctions a real criminal risk for both individuals and companies.

Source: Ministry of Foreign Affairs of Finland, Website of the Swedish Parliament