The so-called UTP Act prohibits buyers from using certain terms and conditions and practices against suppliers of agricultural and food products. The Swedish Competition Authority exercises supervision and can, among other things, carry out unannounced inspections and order individual to attend formal interviews. In conjunction with violations, sanctions such as injunctions subject to a default fine or a sanction fee of up to one per cent of the buyer’s annual turnover can be imposed. The UTP Act will enter into force on 1 November 2021 and will also be applicable to contracts which are entered into prior to this date.
The European Commission has recently issued three opinions regarding the interpretation of asset freeze provisions in certain sanctions legislation pertaining to Central African Republic, Ukraine, Libya and Syria. The opinions are also of relevance for other sanctions regimes which provide for the same or similar restrictions. Therefore, their practical relevance goes far beyond the sanctions regimes in the context of which they were issued and they therefore provide for helpful guidance regarding the required thresholds for sanctions compliance generally.
