Expert Guide to Financial Sanctions Enforcement in Norway

The Norwegian sanctions regimes is grounded in national legislation administered by the Norwegian Ministry of Foreign Affairs (MFA). Sanctions adopted by the EU, which Norway mostly has chosen to align with, are implemented through regulations under the Act of 16 April 2021 No. 18 on the Implementation of International Sanctions (the Sanctions Act).

Norway is not bound by or obligated to implement EU sanctions. When the EU adopts new restrictive measures, the MFA conducts an assessment, and the Norwegian Government decides whether Norway will follow these sanctions.

To date, Norway has adopted most of the EU's sanctions on Russia, with certain exceptions. For instance, sanctions imposed on state-owned Russian broadcasters have not been implemented due to considerations of freedom of speech, and fishing vessels are still permitted to dock in parts of Norway.

It is important to note that when implementing EU regulations, national adjustments may be included. Therefore, the implemented regulations are not exact replicas of EU regulations but establish Norwegian autonomous regimes.

As a result of this implementation process, new EU sanctions - excluding listings of individuals and companies - typically come into force one to three months after their adoption by the EU. Moreover, since EU practices are not legally binding in Norway, local interpretations of the provisions and differing policies may lead to divergent practices. However, the Norwegian Supreme Court has ruled (HR-2023-1246-A) that the interpretation method used by the European Court of Justice (ECJ) on parallel regulations should be given significant weight.

Norway is currently maintaining sanctions against 29 different nations, geographical areas and terrorist organisations. 

A comprehensive list is published by the Directorate for Export Control and Sanctions (DEKSA) and is available here (only in Norwegian).

As of January 1, 2025, DEKSA has the authority to issue export licenses and approvals according to various sanctions regimes.

Norway largely adopts the list contained in the corresponding UN Security Council resolutions and/or EU regulations. An exception is the Norwegian Regulation of 15 December 2015 No. 2103 on restrictive measures against Venezuela, where Norway has adopted a national entity list.

The list of sanctioned individuals and entities is included in each of the Norwegian regulations. These regulations either contain a list of designated parties or refer to a list updated by the UN or the EU. Specifically, regarding the Russian sanctions, the Norwegian regulation refers to the applicable EU consolidated list of sanctioned persons and entities, which is updated in accordance with the EU’s list.

There are no consolidated versions of listed persons and entities.  However, the DEKSA maintains an updated list with references to current legislation here (available only in Norwegian). 

A violation of Norwegian Financial Sanctions is a criminal offence regulated by the Sanctions Act.  Depending on the nature of the violation, it may also be covered by the Norwegian Penal Code of 20 May 2005 No. 28. 

A violation of Norwegian financial sanctions is punishable by imprisonment of up to three years and/or financial penalties.

Additionally, violations of financial sanctions may fall under sections of the Norwegian Penal Code, which could impose higher maximum penalties. A legal entity found guilty of violating Financial Sanctions can also lose the right to operate its business or may be prohibited from operating in certain forms of business.

The Norwegian Police Security Service (PST) is responsible for investigating and prosecuting criminal breaches of Financial Sanctions laws.

In Norway, violations of financial sanctions are penalized through criminal penalties and the criminal justice system. There is no civil enforcement mechanism in Norway. However, there are certain consequences that are not considered criminal penalties under Norwegian law.

DEKSA may revoke, suspend, or restrict an already issued export license if the license is abused, the terms of the license are breached, or in cases of violation of the export control regulations. A breach of Financial Sanctions regulations can also affect a company’s ability to obtain another export license.

In addition, civil parties may have provided for specific penalties in a contract, typically related to the prohibition of supply or other impediments to supply. For example, this could be a consequence of failure to obtain an export license, as assumed at the time the contract was entered into or when the counterparty is listed as a sanctioned entity.

This is not applicable in Norway.

This is not applicable in Norway.

The DEKSA has prepared a comprehensive list of relevant sanction laws and regulations available on their website here. 

The Norwegian sanctions regime is primarily based on EU restrictive measures and the UN sanctions regime. Therefore, the EU web portal here, which offers a visual overview of EU restrictions, is recommended as a valuable source of information. 

Additionally, DEKSA has published guidance on the freeze obligation and frequently asked questions on their webpage here (available only in Norwegian).

Regarding the sanctions against Russia, DEKSA has also released specific guidance here, which is likewise available only in Norwegian.