Sanctions busters beware – Sweden hikes its cap on corporate fines
In January 2020, the cap on corporate fines in Sweden was drastically increased from SEK 10 million to SEK 500 million. The increase was prompted in part by criticism from inter alia OECD that the relatively modest level of the Swedish fine might not serve to fulfil Sweden's international commitments to effectively and proportionally deter, in particular, larger businesses from criminal activity in the line of their business.
In Sweden, the threat of corporate fines is meant to serve as the primary whip at the backs of corporations, necessitating effective procedures for inter alia trade sanctions compliance. The concrete implications of the 50-fold increase are of considerable interest to Swedish corporations. But although the increase may seem like a decisive response to criticism, the actual effects might not be as daunting.
The firm's Corporate Sustainability and Risk Management practice group has recently published an article on the topic with focus on liability for trade sanctions violations. We welcome you to read it here.