Anti-corruption regulation—Sweden—Q&A guide
Anti-corruption regulation—Sweden—Q&A guide

The following Corporate Crime practice note provides comprehensive and up to date legal information covering:

  • Anti-corruption regulation—Sweden—Q&A guide
  • 1. To which international anti-corruption conventions is your country a signatory?
  • 2. Identify and describe your national laws and regulations prohibiting bribery of foreign public officials (foreign bribery laws) and domestic public officials (domestic bribery laws).
  • 3. Can a successor entity be held liable for violations of foreign and domestic bribery laws by the target entity that occurred prior to the merger or acquisition?
  • 4. Is there civil and criminal enforcement of your country’s foreign and domestic bribery laws?
  • 5. Can enforcement matters involving foreign or domestic bribery be resolved through plea agreements, settlement agreements, prosecutorial discretion or similar means without a trial? Is there a mechanism for companies to disclose violations of domestic and foreign bribery laws in exchange for lesser penalties?
  • 6. Describe the elements of the law prohibiting bribery of a foreign public official.
  • 7. How does your law define a foreign public official, and does that definition include employees of state-owned or state-controlled companies?
  • 8. To what extent do your anti-bribery laws restrict providing foreign officials with gifts, travel expenses, meals or entertainment?
  • 9. Do the laws and regulations permit facilitating or ‘grease’ payments to foreign officials?
  • More...

This Practice Note contains a jurisdiction-specific Q&A guide to anti-corruption regulation in Sweden published as part of the Lexology Getting the Deal Through series by Law Business Research (published: November 2020).

Authors: NORDIA LAW—Carl-Johan Allansson; Hans Strandberg; Olle Kullinger

1. To which international anti-corruption conventions is your country a signatory?

Sweden is party to several international anti-corruption conventions; the United Nations Convention against Corruption (ratified in 2007), the Council of Europe Civil Law Convention on Corruption (ratified in 2004), the Council of Europe Criminal Law Convention on Corruption (ratified in 2004) and the Organisation for Economic Co-operation and Development Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (ratified in 1999).

2. Identify and describe your national laws and regulations prohibiting bribery of foreign public officials (foreign bribery laws) and domestic public officials (domestic bribery laws).

The provisions prohibiting bribery of foreign and domestic officials are to be found in the Swedish Penal Code (1962:700) (the Penal Code). The legislation forbids active and passive bribery in relation to anyone who is employed or who holds an assignment. No distinction is made between private and public officials, although passive bribery (bribe taking) and active bribery (bribery) are separated as two different offences.

As supplement to the Penal Code, the Swedish Anti-Corruption Institute, founded in 1923, has published the Code on Gifts, Rewards and other Benefits (the Code

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