Norway

Global sanctions guide

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  1. Does Norway have a sanctions regime in place?

Yes, Norway’s export control regime must be complied with by any individual or entity domiciled or resident in Norway.

  1. Does Norway implement UN sanctions?

Yes.

  1. Does Norway implement an autonomous sanctions regime?

The Criminal Procedure Act provides that persons or enterprises suspected of terrorist activities may have their assets frozen. Furthermore, financial institutions are obliged to report any possible financing of terrorism under the Money Laundering Act. Also, travelling restrictions may be issued by the government authorities under the Immigration Act.

  1. What is the nature of the sanctions regime in Norway?

The export control regime in Norway provides that certain goods, technology and services cannot be exported without an export license issued by the Norwegian Foreign Ministry. This applies to defence equipment, civilian goods, technology and services with potential military application as described in lists that are negotiated within the multilateral export control cooperation that Norway participates in. Both EU Regulations and UN Resolutions do not have direct effect in Norway and they must be implemented in Norway by local legislation. Norway is obligated under international law to implement UNSC binding resolutions and after an assessment Norway can endorse the EU Regulations. Thus, when sanctions or embargoes are set by the UN or the EU, Norway must enact implementing legislation. Export restriction regimes are implemented by Norway individually for each country to which restrictions apply. The most frequently applied measures under Norwegian legislation are: arms embargoes and non-military measures, ie blockage of economical or other connections to third party states.

  1. Does Norway maintain a list of sanctioned individuals and entities?

Norway does not maintain an independent list of sanctioned individuals and entities; it largely adopts the list contained in the corresponding UNSC Resolutions and/or EU Regulations which are implemented as described under question 4.

  1. Are there any other lists related to sanctions?

The Norwegian Ministry of Foreign Affairs has developed two lists which describe: (i) defence equipment and (ii) civilian goods, technology and services with potential military application, which applies to export control. The lists are negotiated within the multilateral export control cooperation that Norway participates in.

  1. Does Norway have a licensing or authorization system in place?

Yes, the Norwegian Ministry of Foreign Affairs can grant individual licences (to one exporter for one delivery/shipment to an identified consignee), or general licences (to one exporter for unlimited shipments within a given period, usually one year, of a specified good to any consignee in one or more countries).

  1. What are the consequences for a breach of sanctions in Norway?

On the assumption that the offence is not subject to a more severe penal provision under the legislation included at question 3 above, the maximum penalty for a violation of the Act on Control of the Export of Strategic Goods, Services and Technology, etc., is fines and/or imprisonment of up to five years.

  1. Who are the relevant regulators in Norway and what are their contact details?

The section for Export Control within the Norwegian Ministry of Foreign Affairs is responsible for the national implementation and administration of export control, both in terms of policy frameworks, legislation and processing of applications for licences.

Norwegian Ministry of Foreign Affairs
Postboks 8114 Dep.
N-0032 Oslo

T: (+47) 23 95 06 50
E: post@mfa.no and lisens@mfa.no


The Financial Supervisory Authority (Kredittilsynet) is responsible for monitoring the compliance of the requirements by the various reporting entities:

Financial Supervisory Authority (Kredittilsynet)
Revierstredet 3
0151 Oslo

T: (+47) 22 93 98 00
E: post@finanstilsynet.no


The Norwegian Police Security Service is responsible for investigations into offences related to terrorist financing.

Contributor law firm

Nina Charlotte Lindbach, Haavind, Bygdøy allé 2, PO BOX 359 Sentrum, 0101 OSLO

T: (+47) 936 292 10
F: (+47) 224 330 01
n.lindbach@haavind.no
www.haavind.no/en