Export controls and sanctions

Norway complies with all sanctions imposed by the UN or the EU. Breaching these sanctions can have serious consequences for a business. Norwegian exporters must therefore ensure that they operate within the sanctions framework.

Norwegian companies need to be aware of both national and international sanctions. Sanctions affecting your company may be imposed by the UN, the EU or the Norwegian government. Sanctions can change quickly depending on the political situation, so you need to keep up to date with developments.

Your company is responsible for ensuring that it does not trade with individuals, organisations or countries subject to sanctions. To stay up to date with current sanctions, check the websites below: 

• The Norwegian Directorate for Export Controls and Sanctions provides a wealth of useful information on its website:
  • Current sanctions provides an overview of the sanctions that apply to Norway 
  • Under News DEKSA publishes news and updates from the Norwegian Ministry of Foreign Affairs.
  • Export control provides information about export licences and how to apply for a licence.
• EU SanctionsMap also provides a clear overview of restrictive measures imposed by the EU and the UN.
• Various consultancy and law firms offer sanctions monitoring services.

When checking that you comply with applicable sanctions and trade restrictions, you need to consider several factors:

• Recipients: Check whether your partner or the country where you operate is subject to sanctions. Your company is responsible for ensuring that it does not breach any sanctions. The know-your-customer principle is important, and a thorough risk assessment of the country, companies and individuals you work with can help your company avoid difficult situations later on. Be aware that third parties may also pose a risk, so make sure you include them in your risk assessment.
• Origin: Consider the origin of the components and technology in your product. Even if you export from Norway, parts of your product may be subject to restrictions imposed by their country of origin. For example, a product exported from Norway that contains US technology may be subject to US trade restrictions and sanctions.
• Technology, software and data: Be aware that data transfers, technology and software may also be subject to restrictions. Make sure your company complies with sanctions, including in the digital sphere.
• Dual-use potential: Determine whether your product or service is a dual-use item. Dual-use items are products that can be used for both civilian and military purposes, such as advanced technology or chemicals. These items may require an export licence, even if they are primarily intended for civilian use.
• Documentation requirements: Establish robust documentation procedures. You must document all transactions and contracts involving parties from sanctioned countries, including the origin of goods and services and any associated export licences. Robust documentation procedures can help protect your business during future audits.

Defence equipment and dual-use items may require an export licence before you can take them out of the country. You must apply for an export licence for both temporary and permanent exports. DEKSA's checklist for companies planning to export strategic goods, services or technology gives you a clear overview of what you need to know.

As an exporter, you should assess whether your products may fall into the categories of strategic goods and services or dual-use items. If you have any questions about how to interpret the regulations, please contact DEKSA.

There are three control lists under the national export regulations. List I covers defence-related products and services, while Lists II and III cover dual-use items. List III entered into force on 1 November 2024 and covers the same categories of goods as List II. List III therefore does not add new categories to the regime, but extends the applicability and scope of the various categories.

Please note that some products and services require an export licence because of their potential use, even if the inputs and technology used in the product or service do not.

Breaching sanctions can have serious consequences for your company, including fines, reputational damage and legal disputes. Individuals may also face imprisonment. Under the Sanctions Act, negligent breaches are punishable by up to six months’ imprisonment, while intentional breaches are punishable by up to three years’ imprisonment: https://lovdata.no/lov/2021-04-16-18. Under the Export Control Act, negligent and intentional breaches are punishable by up to two and five years’ imprisonment respectively: https://lovdata.no/lov/1987-12-18-93. 

To ensure your business complies with all applicable sanctions and trade restrictions, we recommend conducting regular internal audits and updating your compliance programme in line with the latest sanctions. By staying proactive and well informed, you can minimise risk and navigate the export landscape with confidence.