For the fifth consecutive year, CMS Kluge lawyers Siv Madland, Rebekka Asbjørnsen and Ronny Rosenvold have contributed to the sanctions guide published by International Comparative Legal Guides.
The guide provides a comprehensive overview of the key issues in sanctions law in Norwegian law, as well as in 13 other jurisdictions. Over the past year, there have been several relevant changes in sanctions regulation. From a Norwegian perspective, it is particularly important to note the national threat assessment of the Norwegian Police Security Service (PST). The PST highlights that Norwegian research and educational institutions are vulnerable targets for foreign intelligence services, which seek the illegal transfer of knowledge.
In 2023, an Iranian-German professor employed at a Norwegian university was accused of violating sanctions regulations against Iran due to his collaboration with Iranian visiting researchers. The Court of Appeal (LB-2023-40228) concluded that there was no violation, but emphasized that the transfer of knowledge also can be covered by Norwegian sanctions regulations. It is also important to note that as recently as June 2024, the District Court of Hordaland fined a Norwegian bank for violating the sanctions against ISIL, and in particular the obligation to freeze assets belonging to listed individuals. The case has been appealed, and it will be very interesting to see how the Court of Appeal will elaborate on the obligations of financial institutions to act.
Although the number of criminal cases in Norway based on the Sanctions Regulations is limited, it is worth noting that there is an increased focus on enforcement, especially from the EU. This is reflected in the EU's 14th sanctions package, which provides for a more harmonised level of sanctions. Whether Norway will respond to the EU's call is currently uncertain.
The guide also points out a number of other relevant issues, which are very useful for those working with sanctions law in different contexts.
CMS Kluge is recognised as one of Norway's leading law firms in the field of export controls and sanctions. Together with the CMS network of lawyers, we are able to advise our clients on both Norwegian sanctions and multinational multi-jurisdictional assessments.
Read the Norwegian section here: READ HERE
In cooperation with the University of Oslo (IntNatlaw project), CMS Kluge also organises regular network meetings on sanctions law. If you would like to participate in these meetings, please contact us.
