8 Things You Need to Know About the New Sanctions Act

Since the summer of 2025, a new Sanctions Act has been in force in the EU, as set out in Directive (EU) 2024/1226 of the European Parliament. The following explains how Sweden has implemented this legislation.

Under this law, a much wider range of actions that violate international sanctions are considered criminal – including attempts to circumvent sanctions and minor violations. At the same time, the current global situation means that politicians and authorities are under pressure to ensure sanctions are effective. The risk of committing a sanctions offence – knowingly or unknowingly – is now greater than ever.

• The definition of a sanctions offence has been broadened to include not only direct violations but also circumvention.
• The maximum penalty for aggravated sanctions offences has increased from four to six years’ imprisonment.
• The minimum penalty for a standard sanctions offence has been raised from fines to imprisonment.
• A new offence, minor sanctions violation, has been introduced, making even small breaches punishable.
• A new offence, repeated sanctions offence, introduces harsher penalties for those committing multiple violations.
• Attempting or aiding a sanctions offence is now punishable.
• Several authorities are now required to report suspected sanctions offences, increasing the likelihood that violations will be detected.
• The risk for organizations to face corporate fines for sanctions offences has increased.

How to Keep Your Business Compliant with the New Law

To stay ahead and avoid legal and financial consequences, consider the following steps:

• Understand the international sanctions applicable in Sweden.
  Sweden does not impose its own sanctions but follows those issued by the EU and the UN. Conduct a risk analysis of your operations – identify areas with higher exposure to sanctions risks, decide how to manage them, and document your reasoning.
• Establish a sanctions policy.
  Define how risks should be identified on an ongoing basis and how to act if a potential sanctions violation is suspected. Clarify roles and responsibilities within the organization.
• Train your employees.
  Ensure your staff understands the sanctions regulations relevant to your business, the key risks involved, and how to act according to your sanctions policy. Emphasize the importance of everyone’s contribution.
• Document your compliance efforts.
  Keep records of the measures taken to prevent violations – such as what checks were performed, the outcomes, and the rationale behind each decision. Document both transactions you proceeded with and those you declined – demonstrating an active effort to comply can be valuable.
• Let Aunetic Sanctions (formerly Qnister) simplify the process.
  Although this may seem like a large undertaking, Aunetic Sanctions (formerly Qnister) can help you automate much of the work of screening individuals and companies against sanction lists. Use our logging feature to ensure your compliance efforts are properly documented.
• Stay up to date.
  Having an existing agreement with an organization before it was added to a sanctions list is not a valid excuse. Since sanction lists are frequently updated, regular follow-ups are essential. Aunetic Sanctions (formerly Qnister) can help you minimize the effort required to maintain ongoing compliance.

Check your business relationships quickly and easily with our search tool – instantly see if a person or company appears on any sanctions list before starting a new partnership.

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