General Prerequisites

For a crime to have been committed under Swedish law, two conditions must be met: an unlawful act must have taken place, and someone must be capable of being held personally liable for that act. An act – or, in certain situations, an omission – is unlawful where it satisfies the statutory definition of an offence and no justifying grounds, such as necessity or self-defence, apply. A person is personally liable where the unlawful act was committed with requisite intent or negligence, and no excusing grounds apply (such as a reasonable mistaken belief that the act was justified). Motive is not a constituent element and is not required for liability, but is taken into account when determining the sanction.

The general prerequisites for criminal liability, the definitions of the most common offences – including white-collar offences – and the justifying and excusing grounds are all set out in the Swedish Penal Code.

Categories of Offences

Swedish law does not classify offences into different categories such as misdemeanours and crimes. Instead, a single offence can often be categorised into varying degrees of severity. Fraud, for instance, can be classified as minor, of a standard degree, or aggravated.

Attempted Offences

A person who begins to commit an offence but does not complete it may, in cases specifically prescribed by law, be held liable for attempt, provided there was a danger that the act would lead to completion of the offence, or such danger was precluded only because of chance circumstances (Chapter 23, Section 1 of the Swedish Penal Code). This applies broadly across many categories of crime, including to fraud, embezzlement, tax offences, bribery and several other common white-collar offences.

Earlier stages of criminal conduct – preparation and conspiracy – are punishable where expressly prescribed for the offence in question (Chapter 23, Section 2). Among white-collar offences, this applies to, for example, the aggravated forms of fraud, embezzlement, breach of trust against a principal, money laundering and accounting offences. However, a person who voluntarily causes the offence not to be completed – whether by abandoning its execution or in any other way – shall not be held liable for the attempt, preparation or conspiracy (Chapter 23, Section 3).

Burden of Proof in White-Collar Proceedings

Consistent with the presumption of innocence under Article 6(2) of the European Convention on Human Rights, the prosecutor bears the burden of proof in white-collar proceedings, and must establish every element of the offence.

Standard of Proof in White-Collar Proceedings

A conviction requires proof beyond reasonable doubt that the defendant committed the offence. Where reasonable doubt remains, the principle of in dubio pro reo – that doubt must benefit the accused – applies. Swedish law does not generally recognise presumptions operating against the defendant on the question of guilt.

Limitation Periods

Under Chapter 35, Section 2 of the Swedish Penal Code, the limitation period expires if the suspect has not been remanded in custody, served with notification of prosecution, or accepted a summary imposition of a fine for the offence within:

• two years, for offences punishable by up to one year’s imprisonment;
• five years, for offences punishable by more than one and up to two years;
• ten years, for offences punishable by more than two and up to five years;
• fifteen years, for offences punishable by more than five and up to eight years; and
• twenty-five years, for offences punishable by more than eight years.

Pursuant to Chapter 35, Section 10 of the Swedish Penal Code, a narrow category of the most serious offences – such as those punishable by life imprisonment – is exempt from any limitation period.

Most core white-collar offences in their standard degree – including fraud, embezzlement, breach of trust against a principal, and the main accounting and tax offences – carry a maximum of two years’ imprisonment and therefore a five-year limitation period. Where the offence is aggravated, the maximum penalty is typically six years, extending the limitation period to fifteen years.

Calculations of Limitation Periods

Chapter 35, Section 5 of the Swedish Penal Code provides that the limitation period generally runs from the date the offence was committed or, where a specific effect is required for liability, from the date that effect arose. A limited number of exceptions apply, the most relevant for white-collar offences being accounting offences and certain tax offences, as follows.

• For non-minor accounting offences, the period runs from a later triggering event – broadly, formalisation of the company’s financial difficulties (eg, through bankruptcy or a composition arrangement) or a Swedish Tax Agency audit – provided the triggering event occurs within five years of the offence.
• Similarly, under Section 14 of the Tax Offences Act, certain tax offences are subject to a five-year period triggered by a Tax Agency audit.

Except for these specific exceptions, Swedish law has no general rule deferring the limitation period for concealed offences until discovery.

Continuing Offences

For a continuing offence, the limitation period generally runs from the date on which the criminal state of affairs ceases. So long as the final part of the offence is not time-barred, the court may thus impose liability for the entire duration. Exceptionally, so-called successive limitation applies, meaning that liability can only be imposed for those parts of the activity that are not yet time-barred; in practice, charges are often not brought for time-barred parts of a continuing offence.

Laws with Extraterritorial Reach

Swedish courts may exercise jurisdiction over certain offences committed outside Sweden under Chapter 2, Sections 3 and 4 of the Swedish Penal Code. Jurisdiction requires a connection to Sweden, for example through:

• a Swedish vessel or aircraft (eg, an offence committed on board a Swedish-flagged vessel);
• a Swedish perpetrator (eg, bribery or gross bribery committed by a person abroad in the course of a Swedish company’s business activities);
• a Swedish private interest (eg, bribery, gross bribery or influence peddling committed abroad against a Swedish citizen, resident or legal person); or
• a Swedish public interest (eg, an offence committed in the exercise of a position involving Swedish public authority, such as bribery of a foreign official by a Swedish diplomat).

In most of these cases, jurisdiction further requires dual criminality – ie, that the act is also punishable under the law of the place where it was committed – subject to limited exceptions, including offences for which Swedish law prescribes a minimum sentence of four years’ imprisonment or more. Prosecution of such offences also typically requires special authorisation from the Government or the Prosecutor-General, who considers Sweden’s international-law obligations, the offence’s connection to Sweden and any parallel proceedings abroad.

Legal Instruments for Cross-Border Co-Operation

Sweden has multiple instruments for cross-border co-operation in criminal matters, including the Act on a European Investigation Order for evidence-gathering within the EU and the Act on International Legal Assistance in Criminal Matters for other measures and jurisdictions. Sweden has no general blocking statute of its own, but as an EU Member State is directly bound by the EU Blocking Regulation (Council Regulation (EC) No 2271/96), which shields against certain third-country extraterritorial sanctions laws. Beyond that, disclosure to foreign authorities follows the ordinary secrecy rules under the Public Access to Information and Secrecy Act.

Extradition for White-Collar Crimes

Sweden has separate legal frameworks for surrender and extradition depending on the requesting State. Surrender between the Nordic countries and within the EU is governed by the Act on Surrender from Sweden Based on a Nordic Arrest Warrant and the Act on Surrender from Sweden Based on a European Arrest Warrant, respectively, while extradition to other States is governed by the Act on Extradition for Criminal Offences. All three may apply to white-collar offences, subject to a minimum sentence threshold. Extradition, for example, requires an offence punishable by at least one year’s imprisonment, a threshold met by many common white-collar offences, such as fraud and embezzlement.

Swedish Authorities’ Involvement in International Task Forces

Sweden engages extensively in international co-operation in criminal matters, largely within the EU framework but also more broadly, including through FATF, the OECD Working Group on Bribery, INTERPOL, Europol, Eurojust, the European Public Prosecutor’s Office and the European Judicial Network.

Corporate Criminal Liability and Corporate Fines

Under Swedish criminal law, only natural persons can be held criminally liable – legal entities cannot. However, a legal entity may be subject to a corporate fine for offences committed in the course of its business.

A corporate fine may be imposed where the offence carries a penalty above a fixed monetary fine (penningböter); the offence was committed in the course of the company’s business operations; and either the company failed to take reasonably required preventive measures or the offence was committed by someone in a leading or supervisory position (Chapter 36, Section 23 of the Swedish Penal Code).

As a general rule, both individual criminal liability and a corporate fine may be imposed for the same offence committed in a company’s business. For negligent offences that cannot be expected to result in a sanction more severe than a fine, however, the corporate fine is the primary sanction, and individual prosecution may be pursued only if called for from a public-interest perspective (Chapter 36, Section 27 of the Swedish Penal Code). Beyond that threshold, charges against the individual and the corporate fine against the company are typically brought in the same proceedings and decided by the court in a single judgment.

Personal Liability for Managers and Directors

A corporate fine does not in itself trigger personal liability for managers or directors. However, individual liability may arise on independent grounds – for instance, where an officer’s own conduct satisfies the elements of an offence, whether as perpetrator, accomplice or instigator. In addition, Swedish law recognises a form of guarantor liability (företagaransvar) under which an officer in a leading position has a duty to ensure that the business is organised and conducted in accordance with applicable law. Where such an officer fails to organise the business properly or to exercise adequate supervision, they may be held personally liable for offences resulting from that failure (subject, as with any offence, to the applicable requirement of intent or negligence being met by the individual).

Parent-Subsidiary Liability and M&A

A corporate fine attaches to the legal entity in whose business the offence was committed; a parent company is not subject to a corporate fine for offences committed in the course of a subsidiary’s business (though it may be independently exposed where the offence is attributable to its own business).

Where a legal entity subject to a corporate fine is merged with another legal entity, be it by way of absorption or combination, the corporate fine passes as part of the universal succession in the same way as any other liability of the transferring company and may be enforced against the acquiring company. By contrast, where there is no universal succession (eg, in share and asset deals), the entity in whose business the offence was committed – ie, the target company itself in a share deal, or the transferring entity in an asset deal – remains solely exposed to the corporate fine.

Assessment of Penalties

Sentencing for white-collar offences follows the general rules in Chapters 29 and 30 of the Swedish Penal Code. In short, the court first determines the penal value of the offence within the statutory range and then, taking into account any aggravating and mitigating circumstances, arrives at a sentencing value on the basis of which it chooses between a custodial sanction (imprisonment) and a non-custodial sanction (a conditional sentence or probation, in each case alone or combined with a fine).

For legal entities, the ordinary corporate fine ranges from SEK5,000 to SEK10 million, set according to the seriousness of the offence, the harm or danger caused, the offending’s relationship to the business, and any prior corporate fines. For larger enterprises (as defined in the Swedish Annual Accounts Act), the fine may be significantly higher – up to a maximum of SEK500 million – and must be set at a level reflecting the company’s financial position.

All sanctions are determined by the court in the same judgment as the conviction; there is no separate sentencing hearing.

Alternative Resolution: Summary Orders, Waiver of Prosecution, Co-operation Discount

Swedish law does not recognise deferred or non-prosecution agreements or plea bargaining. However, domestic mechanisms produce broadly similar outcomes in certain circumstances, as discussed in 2.7 Deferred Prosecution and 4.3 Plea Agreements, Co-Operation, Self-Disclosure and Leniency.

Mitigating Factors, Compliance and Remediation

As noted in 1.5 Corporate and Personal Liability, a corporate fine may only be imposed where the company failed to take reasonably required preventive measures, or the offence was committed by a person in a leading or supervisory position. Implementing and genuinely applying a well-designed compliance programme is one way of taking such preventive measures, and can be decisive. If a company can show that reasonably required preventive measures were in fact taken, then the threshold for a corporate fine is not met, and no fine can be imposed. If liability is nonetheless established, the fine may be reduced – and, in particularly compelling cases, waived – where the company has tried to prevent, remedy or limit the harmful effects, has voluntarily reported the offence, or where other special reasons for adjustment exist.

Legal Grounds and Conditions for Compensation

Compensation for victims of white-collar offences is grounded in general tort law and pursued primarily within the criminal proceedings. The most common route is the adhesion procedure. Under Chapter 22, Section 1 of the Swedish Code of Judicial Procedure, a civil claim arising from an offence may be joined with the prosecution; otherwise, it must be brought as an ordinary civil action. A distinctive feature of Swedish practice is that the prosecutor is obliged to prepare and pursue the civil claim alongside the indictment at the victim’s request, provided this can be done without material inconvenience and the claim is not manifestly unfounded. Victims of white-collar offences of limited scope and complexity can therefore often recover damages without having to engage their own counsel.

Jurisdiction

Damages claims are heard by the general courts – District Courts at first instance, with appeal to the Courts of Appeal and, on points of precedent, to the Supreme Court. There is no separate civil court: the same District Court hears the criminal case and any adhesive civil claim, which underpins the practical dominance of joint handling in a single forum.

Collective Redress

Sweden has a general opt-in class action regime, but it is rarely used for white-collar offences. In practice, similar results are often achieved indirectly through the prosecutor pursuing many victims’ adhesive damages claims within a single criminal trial.

Criminal Enforcement Authorities

Responsibility for investigating and prosecuting white-collar offences is divided mainly between two prosecutorial authorities. The Swedish Prosecution Authority, together with the Swedish Police Authority, handles most criminal offences, including common forms of white-collar offences. The Swedish Economic Crime Authority, which has its own dedicated police officers, is responsible for investigating and prosecuting complex economic crime linked to business activities, such as large-scale money laundering, tax offences and market abuse. The ordinary prosecution service also has specialised units for certain categories of white-collar offence, notably the National Anti-Corruption Unit. Sweden does not have specialised judges or courts for white-collar offences; such cases are tried by the general courts.

Civil and Administrative Enforcement Authorities

White-collar misconduct may also attract investigation and sanction by administrative authorities. The Swedish Financial Supervisory Authority, the Swedish Tax Agency and the Swedish Authority for Privacy Protection may each, within their respective areas, investigate breaches and impose administrative fines.

As a rule, the same conduct will not give rise to both criminal and administrative sanctions against the same person for the same offence, because Swedish law applies the ne bis in idem principle. In practice, the criminal and administrative tracks are often co-ordinated through legislative allocation rules – for example, serious, intentional market abuse is prosecuted criminally, while less serious violations are handled administratively by the Swedish Financial Supervisory Authority.

The Influence of Public Policy and Political Pressure

Enforcement of white-collar offences has become a growing priority as Sweden steps up its efforts against gang-related crime, which generates substantial proceeds through economic crime such as welfare fraud, money laundering and tax offences. Combating classic white-collar offences is therefore increasingly framed as a means of disrupting the criminal economy and the financial foundations of criminal networks. Reflecting this shift, the Government has presented targeted proposals intended to strengthen the tools available to the Swedish Economic Crime Authority and the Swedish Police Authority in combating the criminal economy, including giving the two authorities access to additional registers and enabling more law-enforcement agencies to assist the Swedish Enforcement Authority with remote distraint. A further example of these intensified enforcement efforts is the new Chapter 36 of the Swedish Penal Code, which, together with a new procedural act on the confiscation of property and corporate fines that entered into force on 8 November 2024, introduces a form of forfeiture allowing property derived from criminal activity to be forfeited even where no individual can be held criminally responsible for a specific offence.

Under Chapter 23, Section 1 of the Swedish Code of Judicial Procedure, a preliminary investigation must be opened as soon as there is cause to believe that a criminal offence subject to public prosecution has been committed. Preliminary investigations into white-collar offences may be opened by the police or by one of the two prosecution authorities (see 2.1 White-Collar Enforcement Authorities). Their duty to investigate a crime may be triggered by, for example, a criminal complaint from an individual or a company, a referral from a supervisory authority, or information from police intelligence or media reports.

General Investigative Powers

Depending on the seriousness of the offence, investigating authorities may conduct interrogations, seize evidence and property, search premises, and deploy various forms of covert surveillance. Coercive measures may be imposed only where the benefit of the measure outweighs the intrusion or other detriment it causes to the suspect or another affected interest.

Producing Documents

Under Chapter 38, Sections 2 and 4 of the Swedish Code of Judicial Procedure, investigating authorities may request that a court order a person holding documents presumed to be of evidentiary significance to produce them. In line with the privilege against self-incrimination, this does not apply to an individual suspect or to a company exposed to a corporate fine or forfeiture. In practice, document production orders are relatively rare in criminal investigations, since the rules on searches and seizure of evidence serve the same purpose more efficiently.

Searching and Seizing Documents

Investigating authorities may search houses, rooms or closed storage spaces where there is probable cause that an offence punishable by imprisonment has been committed (Chapter 28, Section 1 of the Swedish Code of Judicial Procedure). The premises of a person or entity not suspected of the offence may be searched only if the offence was committed there, the suspect was apprehended there, or extraordinary reasons indicate that the search will reveal an object subject to seizure or other relevant information. Documents reasonably presumed important to the investigation may then be seized (Chapter 27, Section 1). However, documents held by a person bound by a duty of confidentiality, and presumed to contain information covered by that duty, are exempt from seizure (Chapter 27, Section 2).

Questioning Employees

During investigations of white-collar offences, anyone reasonably likely to possess information relevant to the inquiry – including employees, officers and directors of companies under investigation – may be questioned (Chapter 23, Section 6 of the Swedish Code of Judicial Procedure). A summons may carry a fine for non-compliance, and a person who disregards it without a valid excuse can be brought into custody for questioning. A person is not, however, obliged to make a statement to the police; the obligation to testify under oath arises only at trial (Chapter 36, Section 1), although, in exceptional cases, the court may order a pre-trial witness examination under Chapter 23, Section 13. Even then, a witness is not obliged to incriminate themselves, may not normally be heard on matters covered by a statutory duty of secrecy, and may refuse to disclose a trade secret absent extraordinary reasons.

Tracing, Freezing and Seizing Digital Evidence and Assets

Authorities investigating white-collar offences can trace digital evidence and assets in several ways. Locally stored information (eg, on a computer) is subject to the ordinary rules on seizure, while information stored on cloud services may be examined through remote search, provided there is reason to believe that an offence punishable by imprisonment has been committed. In investigations into serious criminal activity, digital evidence and assets may also be traced through secret interception of electronic communications. Once relevant information has been located, the company holding it may be subject to a freezing order and thereby obliged to preserve it for up to 180 days. Information identified as significant to the investigation may then be seized or copied, and cryptocurrency and other digital assets may be seized where someone has been deprived of them through an offence or they are liable to forfeiture.

The Use of Technology

The full extent to which AI is used in white-collar investigations in Sweden is not publicly known. Nevertheless, it is clear that investigative authorities have begun to use AI for certain purposes. For example, as of 1 July 2026, the Swedish Police Authority may use real-time facial-recognition AI systems for law-enforcement purposes, and the Swedish Tax Agency uses AI to automate time-consuming tasks such as information gathering, categorisation and transcription in order to detect tax offences more effectively, and to carry out in-depth analyses of complex bank-account transactions.

The Regulation of Technology

Certain uses of AI in criminal investigations are governed by dedicated legislation, notably the Act on the Use of Real-Time Remote Biometric Identification AI Systems for Law-Enforcement Purposes. Other uses are governed by the EU AI Act and, where applicable, the General Data Protection Regulation. Enforcement authorities may accept AI-enhanced investigations conducted by companies, as the principle of free evaluation of evidence applies in Sweden.

The Voluntary Nature of Internal Investigations

Internal investigations are, in principle, neither mandatory nor necessary in Sweden. They may be conducted voluntarily and, by virtue of the principle of free evaluation of evidence, may be considered by enforcement authorities and courts. One exception to the absence of a mandatory requirement is the whistle-blower regime, which requires companies with 50 or more employees to establish internal reporting channels and follow-up procedures.

The Framework Governing Internal Investigations

Where an internal investigation is carried out, it must comply with applicable data-protection and employment-law requirements. For example, the processing of employees’ personal data must rest on a valid legal basis, and particular care is required where the investigation involves special categories of personal data. Breach of these requirements may, among other things, give rise to damages liability for the company that carried out the investigation.

Disclosure of Internal Investigation Findings

Companies are under no obligation to disclose the findings of an internal investigation to enforcement authorities. Where the investigation has been conducted or supervised by a lawyer, or its findings are subsequently entrusted to a lawyer for the purpose of legal advice, the material may be protected by legal professional privilege and exempt from seizure (see 2.3 Powers of Investigation).

A principle of mandatory prosecution applies under Chapter 20, Section 6 of the Swedish Code of Judicial Procedure. A prosecutor is obliged to bring charges where there are sufficient grounds to do so – that is, where a conviction can be anticipated on objective grounds – and this applies in the same way to white-collar offences as to other offences. By way of exception to this otherwise absolute duty, a prosecutor may waive prosecution in certain statutory situations, provided no significant public or private interest is disregarded (Chapter 20, Section 7 of the Swedish Code of Judicial Procedure).

Swedish law does not provide alternative mechanisms such as deferred or non-prosecution agreements for resolving white-collar investigations. A criminal investigation may, however, be resolved without a trial by accepting a summary imposition of a fine. Under Chapter 48, Section 4 of the Swedish Code of Judicial Procedure, a summary imposition of a fine may be issued in three situations:

• where a fine is included in the range of punishment;
• where it is likely that the court would impose a conditional sentence, or such a sentence combined with a fine; and
• where a corporate fine not exceeding SEK3 million would otherwise be imposed.

In addition, for tax offences both criminal prosecution and administrative fines may be avoided through voluntary correction of an inaccurate statement, under Section 12 of the Tax Offences Act (criminal liability) and Chapter 49, Section 10 of the Tax Procedures Act (tax surcharge).

Swedish law does not recognise the concept of ”criminal company law” as such – companies cannot commit crimes (see 1.5 Corporate and Personal Liability). Crimes committed by a company’s representatives or employees may nonetheless have significant consequences for the company itself. The company may be subject to a corporate fine, forfeiture of any proceeds of the offence and damages liability, and may face exclusion from public procurement and reputational harm.

In addition to offences described hereafter in 3. White-Collar Offences, the principal corporate-fraud offences are fraud, embezzlement and breach of trust against a principal. The penalty scales for these offences for an individual perpetrator range from a fine (for the minor form) to imprisonment of up to two years (standard form) and from six months’ to six years’ imprisonment (aggravated form). In addition to any fine or term of imprisonment, individuals may be held liable in damages for offences they have committed and may be subject to forfeiture of any proceeds of the offence.

Bribery is prohibited in both the private and public sectors. Bribery of foreign public officials is also criminalised and may fall within Swedish jurisdiction, inter alia, where the offence is committed by a Swedish national or in the course of a Swedish company’s business operations.

Both givers and receivers may be held criminally liable. The law penalises offering, promising, requesting and accepting an improper benefit – or accepting a promise of such a benefit – for the performance of any employment or assignment. The maximum penalty is six years’ imprisonment.

The notion of improper benefit is not defined by statute; it is assessed on a case-by-case basis having regard to all relevant circumstances. The assessment is stricter where the recipient is a public official. A benefit may be improper regardless of its value. Therefore, there is no de minimis defence.

In addition to bribery, Swedish law criminalises influence peddling and negligent financing of bribery offences. The maximum penalty is two years’ imprisonment.

Swedish law does not impose a specific obligation on companies or individuals to prevent bribery or influence peddling, and there is no general obligation to maintain a compliance programme. However, members of the board of directors and management may under certain circumstances be held criminally liable if they fail to exercise adequate supervision and control over employees and other representatives (see 1.5 Corporate and Personal Liability).

The law does not define what “adequate supervision and control” means, but implementing and genuinely applying a compliance programme tailored to the company’s business is an important means for the board and management to discharge their responsibilities. Maintaining a compliance programme is therefore not mandatory, but in most cases advisable.

There is no obligation under Swedish law to report suspected bribery to authorities.

The market abuse offences under Swedish law implement the EU Market Abuse Regulation. The law criminalises insider trading, market manipulation and unlawful disclosure of inside information. Criminal liability requires intent. For insider trading and market manipulation, the penalty scale extends up to four years’ imprisonment for the aggravated form; unlawful disclosure of inside information carries up to two years’ imprisonment.

The Swedish Financial Supervisory Authority monitors and investigates compliance with the Market Abuse Regulation and reports suspected criminal offences to the prosecutor. The Authority may also impose administrative sanctions on individuals and legal entities for violations of the Regulation. Administrative sanctions are alternative to any criminal charges.

In addition to the market abuse offences, Swedish law criminalises intentional or grossly negligent engagement in financial activities for which a licence or registration is required. The penalty for unauthorised financial activities is a fine or up to six years’ imprisonment.

Intentional tax evasion involves submitting false or incomplete tax returns, or failing to file them, causing underpayment of tax. The penalty scale ranges from a fine to six years’ imprisonment for the aggravated form. Grossly negligent submission of inaccurate tax returns is also criminalised, but carries a lower maximum of two years’ imprisonment. In addition, the Swedish Tax Agency may impose a tax surcharge of up to 40% of the tax that would otherwise have been avoided. Tax surcharges can be imposed on both individuals and legal entities.

A voluntary correction made on the taxpayer’s own initiative may prevent criminal sanctions in certain conditions.

Swedish law imposes no specific obligation to prevent tax evasion, and no related reporting requirements.

The principal offences relating to financial record-keeping are accounting fraud and obstruction of tax audit.

Accounting fraud consists of the intentional or negligent violation of accounting obligations by failure to record business transactions or retain accounting information, or by providing inaccurate information in the accounting records, where as a result the company’s course of business, financial results or financial position cannot be assessed on the basis of those records. The penalty scale ranges from a fine up to six years’ imprisonment.

Obstruction of tax audit consists of the intentional or grossly negligent failure to comply with accounting obligations or obligations to maintain and preserve records, if the failure creates a risk that the authorities’ audit activities in connection with the calculation or collection of taxes or fees will be seriously impeded. The penalty scale ranges from a fine up to four years’ imprisonment.

Swedish law contains no criminal antitrust offences. Cartels and abuse of a dominant position are, however, prohibited under Swedish and EU competition law. Breaches are sanctioned administratively – principally through fines of up to 10% of the undertaking’s annual turnover, full immunity for the first cartel participant to self-report to the Swedish Competition Authority (with reductions for later reporters), damages, exclusion from public procurement and, for members of management, a trading prohibition.

Swedish law contains no criminal consumer-protection offences. Consumer rights are enforced within the private-law regime, supplemented by administrative powers vested in regulators. For example, authorities may prohibit – and impose administrative fines in relation to – unfair contract terms and unlawful marketing.

Swedish law is largely technology-neutral. In principle, most offences can be committed using a computer, mobile phone or other electronic communication device. Phishing, for example, is prosecuted under the ordinary fraud provision. With a few exceptions, there are no cyber-specific offences under Swedish law. A notable exception, described below, is computer intrusion.

A person who unlawfully accesses data intended for automated processing, or unlawfully alters, deletes, blocks or enters such data into a register, may be convicted of computer intrusion – cyber-attacks being a typical example. A person who unlawfully accesses an electronic communications network may be convicted of violation of postal or telecommunications secrecy. The ordinary penalty scale for both offences is a fine or up to two years’ imprisonment, rising to up to six years for aggravated computer intrusion.

The intentional and unlawful obtaining, use or disclosure of trade secrets is a criminal offence, punishable by a fine or imprisonment of up to six years.

The sanctions regimes applicable in Sweden are based on UN and EU sanctions. Their importance to financial institutions and companies engaged in international trade has grown markedly in recent years as a result of the EU’s successive sanctions packages targeting Russian entities and individuals following the Russian invasion of Ukraine.

Under Swedish law, sanctions are enforced criminally rather than administratively, and breaches may give rise to individual criminal liability. Making funds or economic resources directly or indirectly available to a sanctioned person or entity, or circumventing EU sanctions, constitutes a sanctions offence when committed with intent or gross negligence. The penalty ranges from a fine to six years’ imprisonment.

The Act of International Sanctions contains a humanitarian exemption providing that acts do not constitute criminal offences where they relate to humanitarian aid, support for basic human needs or similar assistance. The exemption has not yet been tested in court and its scope remains unclear.

Smuggling and other import and export offences are criminalised under Swedish law. The penalty scale ranges from a fine to six years’ imprisonment, rising to up to ten years where the offence concerns narcotics or weapons.

The privilege against self-incrimination is a fundamental right, so concealing one’s own offence is not criminalised under Swedish law.

Concealing another person who has committed an offence, helping that person to escape, destroying evidence or in any similar way preventing the offence from being discovered or anyone from being prosecuted is a criminal offence, punishable by a fine or up to six years’ imprisonment. False statements made under oath, for example to secure an acquittal, may constitute perjury, punishable by between six months’ and six years’ imprisonment.

The concealment offences cover any predicate offence. The offender will be convicted only of the concealment, not the predicate offence.

Swedish law recognises individual criminal liability for aiding and abetting in relation to virtually all criminal offences. Anyone who, in any way, contributes to an offence, or induces another to commit one, may be punished. Conspiring to commit an offence is also criminalised.

The penalties for aiding and abetting are, in principle, equivalent to those for the principal offence, but the sentence imposed on a secondary participant is in practice often lower than that on the principal.

Swedish law criminalises money laundering, which consists of acts intended to conceal the fact that money or other assets derive from an offence or criminal activity. Any offence can serve as a predicate offence, including foreign offences.

As a general rule, the prosecutor must prove intent in relation to all constituent elements. For minor offences, however, it suffices to prove that the defendant did not realise, but had reasonable grounds to assume, that the property derived from an offence or criminal activity. A further, heightened standard applies to persons acting on behalf of a business or within the course of a business activity: participating in the transmission of funds in that capacity is criminalised already where it is reasonable to assume that the funds are being transmitted to conceal their unlawful origin.

The penalty scale for money laundering ranges from a fine to six years’ imprisonment.

Designated entities – including financial institutions, real estate brokers and law firms – are required to maintain effective risk-management systems, conduct customer due diligence and report suspected money laundering to the Swedish Financial Intelligence Unit. Regulators supervise compliance and may impose administrative sanctions for breaches.

Sweden does not recognise ESG-specific criminal offences as such; general provisions apply instead. For example, intentional or negligent pollution of ground, water or air constitutes environmental crime, punishable by a fine or up to six years’ imprisonment. Trafficking in human beings and forced labour are also criminalised, punishable by between two and ten years’ imprisonment.

Swedish law contains no AI-specific criminal offences. General offences such as market manipulation (see 3.4 Insider Dealing, Market Abuse and Criminal Banking Law) and fraud (see 3.1 Criminal Company Law and Corporate Fraud) apply where AI or algorithms are used unlawfully.

Under the EU Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114), crypto-assets are classified as asset-referenced tokens, e-money tokens or other crypto-assets.

Swedish law contains no crypto-specific criminal offences. Instead, general provisions apply. Illicit handling or trading with crypto-assets may, for example, constitute money laundering (see 3.13 Money Laundering), fraud (see 3.1 Criminal Company Law and Corporate Fraud) or a market abuse offence (see 3.4 Insider Dealing, Market Abuse and Criminal Banking Law).

The Swedish Financial Supervisory Authority oversees compliance with the EU Markets in Crypto-Assets Regulation. Violations may give rise to administrative sanctions, including fines of up to the highest of EUR 15 million, 15% of the undertaking’s annual turnover, or three times the proceeds of the violation.

Common defences include both general strategies applicable to all offences and some more specific to white-collar matters, as follows.

• Evidentiary gaps – the prosecutor has not met the burden of proving each element of the offence beyond reasonable doubt.
• Lack of intent – the defendant does not meet the subjective requirement for the offence. Intent, or in some cases negligence, is a necessary element of all criminal offences. Several white-collar offences in addition require that the defendant knowingly breached an underlying rule (eg, violated a prohibition or acted without a required permit); lack of such knowledge, including through reasonable reliance on external advice, is a common defence.
• Lack of relevant responsibility – the defendant did not hold the relevant responsibility within the company, for example for compliance, financial record-keeping or ensuring that necessary permits are in place. Where the defendant did hold such responsibility, a viable defence may be that he or she was not given the training or resources to discharge it, so that responsibility instead rests with management or the board.

The existence of an effective compliance programme is not per se a defence to criminal charges. It may, however, be a relevant factor in assessing whether an otherwise responsible individual – for example, a director or officer – took adequate measures to prevent offences within the organisation. For companies, it may also preclude the corporate fine where it shows that the company had taken reasonably required preventive measures (see 1.5 Corporate and Personal Liability).

Several white-collar offences carry a built-in threshold below which conduct is not criminal at all, or is downgraded to a lesser, petty offence – a proportionality-based limitation on the more serious charge. For certain offences (eg, in the tax and customs area), a prosecution-review requirement applies in addition. In such cases, a prosecution may be brought only where particular reasons warrant it.

No particular industry or sector is exempt from prosecution under Swedish law.

No Plea Bargaining

A criminal charge must – with certain exceptions – be tried by a court. There is, accordingly, no mechanism by which the prosecutor can promise a reduced charge or sentence in exchange for a guilty plea. A summary imposition of a fine or a conditional sentence – whereby the suspect admits the offence and accepts the proposed penalty – may resolve certain less serious cases without a trial, but does not constitute a negotiated plea agreement (see 2.7 Deferred Prosecution).

Self-Disclosure and Co-Operation

The fact that a defendant has voluntarily come forward, or has provided information of material value to the investigation of the offence, may nonetheless be taken into account at sentencing. The same applies to information of material value to the investigation of another person’s offence carrying a minimum penalty of six months’ imprisonment, and to attempts to prevent, remedy or limit the harmful effects of the offence. A confession made once the evidence is already conclusive does not, however, suffice. Where the prosecutor considers that co-operation should affect the sentence, this must be flagged in the indictment, but it is for the court alone to determine what weight, if any, to give it.

Where there are special reasons, these circumstances may justify a sentence below the statutory minimum and, where imposing any sanction would be manifestly unreasonable, the court may waive the sanction altogether. Similarly, a corporate fine may be reduced, or in exceptional cases waived, where the company has voluntarily reported the offence or tried to prevent, remedy or limit its harmful effects (see 1.6 Sentencing and Penalties).

Other Leniency Measures

The prosecutor may waive prosecution in certain statutory situations, provided no significant public or private interest is disregarded (see 2.6 Prosecution). Such a decision does not involve any agreement with the defendant.

For certain offences – for example, in the tax, customs and subsidy areas – statutory provisions grant exemption from liability for voluntary self-correction (see 2.7 Deferred Prosecution and 3.5 Tax Fraud). These provisions apply only where the correction is genuinely self-initiated.

Protection of Whistle-Blowers

Whistle-blowers are protected under the Protection of Whistle-Blowers Act (2021:890), which implements the EU Whistleblower Directive (2019/1937). The Act protects persons who report information about wrongdoing that is in the public interest to disclose. It shields reporting persons from liability for breaching a duty of confidentiality or for the manner in which they obtained the information, provided they reasonably believed the report was necessary to expose the wrongdoing. It further prohibits employers from hindering reporting or retaliating against the reporting person or closely connected individuals, and provides damages for both economic loss and non-economic harm. The burden of proof is partly reversed in such disputes.

A reporting person may choose freely between internal reporting and an authority’s external reporting channel. The protection afforded by the Act to reports made to an authority outside its designated external channels is, however, conditional on the reporting person having first made an internal report, and the protection for public disclosure is conditional on a prior external report, unless there are justifiable grounds for reporting or disclosing directly.

Incentives to Report White-Collar Offences

Swedish law provides no financial rewards for whistle-blowers; the focus is on protection against retaliation. A whistle-blower who participated in the offence may, however, receive a reduced sentence for providing information of material value to the investigation (see 4.3 Plea Agreements, Co-Operation, Self-Disclosure and Leniency). Where the irregularities are especially serious – for example, serious economic crime – the justifiable grounds exception allows a report to be made directly to an authority, or disclosed publicly, without first using the internal channel.

Safeguards and Internal Procedures Implemented by Companies

Under the Protection of Whistle-Blowers Act, companies with 50 or more employees must establish internal reporting channels and follow-up procedures. Such companies must appoint independent, impartial persons or units authorised to receive reports, maintain contact with reporters and follow up on what is reported. The channels must allow reporting both in writing and orally (and in person on request), with acknowledgement of receipt within seven days and feedback on follow-up action within three months. Companies must keep reports confidential as to the reporter’s identity, retain documentation for no longer than two years after a case is closed, and are subject to supervisory orders enforcing these requirements.

Anonymous Reporting Channels Provided by Regulators or Prosecutors

The Swedish Government has designated a number of authorities as providers of external reporting channels, including the Swedish Economic Crime Authority. The Economic Crime Authority’s channel may be used by those who, in a work-related context, wish to report irregularities concerning the EU’s financial interests in Sweden. Reports may be made anonymously and may concern fraud, misuse of subsidies, certain customs and VAT offences, acts in breach of the conditions for EU funding, false certification in certain cases, corruption, double funding and similar conduct.

Reports are handled by a special, independent unit within the Authority, which operates autonomously from the rest of the organisation.

In addition, the constitutional freedom to communicate information for publication allows anyone, with limited exceptions, to provide information anonymously to the media, and public authorities may not inquire into the source’s identity.

Where a white-collar investigation or prosecution spans several jurisdictions, the defence must be planned from the outset around the interaction between Swedish rules, EU co-operation instruments and the law of the other States involved. The timing and shape of defence work in Sweden are often driven by requests for mutual legal assistance, European Investigation Orders or surrender under a European Arrest Warrant, which can escalate the pace of events – and the exposure of a client – well before a Swedish prosecutor would normally bring charges.

Early and continuous co-ordination with foreign counsel is important. Common issues include divergent approaches to legal professional privilege, restrictions on cross-border transfers of personal data and documents (notably under the GDPR and sector-specific secrecy rules) and the risk that voluntary disclosure in one jurisdiction is used as evidence in another.

A defendant can rely on several recognised limits to cross-border co-operation, including:

• dual criminality, which generally conditions mutual legal assistance involving coercive measures, extradition and surrender (subject to listed exceptions under the European Arrest Warrant framework);
• the specialty principle, which prevents a person surrendered to Sweden from being prosecuted or punished for other pre-extradition offences without the requested State’s consent;
• human-rights and fair-trial safeguards, together with the public-policy grounds on which assistance must be refused where it would conflict with Sweden’s fundamental legal principles, breach State sovereignty or endanger national security; and
• ne bis in idem under Chapter 2, Section 9 of the Swedish Penal Code and Article 50 of the EU Charter of Fundamental Rights, which generally bars a Swedish prosecution for the same conduct after a final judgment abroad, subject to cumulation of criminal and administrative proceedings in limited circumstances where the proceedings pursue complementary objectives and the aggregate sanction is proportionate.

Three of the more distinctive trends shaping the Swedish white-collar enforcement landscape are set out below.

Sanctions Enforcement Under the Spotlight

Enforcement of international sanctions has moved to the top of the agenda. In September 2026, the Swedish National Audit Office opened an inquiry into whether the Government and the 19 authorities with sanctions-related responsibilities have been given the conditions needed to implement and enforce the EU sanctions regime effectively. The inquiry responds to a persistent concern that, despite signs of systematic circumvention, Swedish authorities have opened very few sanctions investigations and brought even fewer prosecutions compared to neighbouring jurisdictions, such as Finland. The legislative framework has in parallel been reinforced, with the Act on International Sanctions – which broadened the criminal offence of sanctions violations – entering into force on 1 July 2025. We expect enforcement to intensify in the year ahead, both in terms of the number of investigations opened and the resourcing of the Swedish Economic Crime Authority and the Swedish Prosecution Authority.

Unauthorised Financial Activities – From Administrative to Criminal Enforcement

Enforcement against unauthorised financial activities has undergone a structural shift. On 1 March 2026, the Act on Penalties for Unauthorised Financial Activities entered into force, criminalising intentional or grossly negligent engagement in financial activities for which a licence or registration is required (see 3.4 Insider Dealing, Market Abuse and Criminal Banking Law). The Swedish Financial Supervisory Authority is now obliged to report suspected offences to the police. The criminal track has thus become the primary route of enforcement, replacing the previous administrative-led approach that relied on the withdrawal of licences and injunctions. The first investigations and, in due course, prosecutions under the new regime can be expected to emerge during the year ahead.

A Tougher Criminal Sanctions System

In recent years the Swedish Government’s criminal-policy priority has been a sustained toughening of the sanctions system, driven in large part by the response to serious gang-related crime. The reforms are not confined to that area: a wide range of offences, including several core white-collar crimes, now carry heavier penalty scales, and the explicit legislative aim is that custodial sanctions should be imposed more frequently and for longer terms than before. For corporate clients, this translates into longer limitation periods for aggravated offences, greater personal exposure for directors and officers, and a strengthened forfeiture regime (see 2.1 White-Collar Enforcement Authorities) that reaches assets even where no individual is ultimately convicted.