More than 25 years after becoming an original signatory to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, Sweden’s framework for corporate liability remains fundamentally non-compliant with the Convention’s requirements, despite some legislative changes.

While there have been positive developments, the overall state of foreign bribery enforcement against both natural and legal persons continues to raise serious concerns. Sweden has imposed minimal sanctions against four natural persons, and has never sanctioned a company for foreign bribery, underscoring the urgency of reform. Enforcement efforts remain hampered by the deficient legal framework, resource and expertise gaps among law enforcement in respect of foreign bribery, and judicial interpretations that may impose excessively high standards of evidence.

The 46-country Working Group has just completed its Phase 4 evaluation of Sweden’s implementation of the Anti-Bribery Convention and related instruments. In addition to the aspects highlighted above, the report details further areas for improvement of Sweden’s effectiveness in preventing, detecting, and enforcing the foreign bribery offence. The Working Group acknowledges Sweden’s willingness to address these shortcomings and is encouraged by the ongoing Legislative Inquiry on 'Measures under criminal law against corruption and official misconduct’. With the Inquiry’s final report expected in July 2025, the Working Group urges Sweden to share its findings with members of the Inquiry, and the legislature, to ensure it fully capitalises on this opportunity.

The Working Group recommends that Sweden, among other things:

• Clarify interpretation issues related to the foreign bribery offence, such as bribery involving third parties acting outside their scope of engagement.
• Confirm that liability of legal persons is explicitly and practically not dependent on the prosecution or conviction of a natural person.
• Ensure that legal persons can be held liable for foreign bribery committed through intermediary entities, including related legal persons and other third parties.
• Ensure sanctions for legal persons for the foreign bribery offence are effective, proportionate, and dissuasive, in law and in practice.
• Strengthen the enforceability of foreign bribery-related false accounting offences.

The report also highlights positive aspects of Sweden’s efforts to fight foreign bribery. These include Sweden’s strong commitment to global anti-corruption efforts demonstrated by its official development aid programme, which supports capacity-building, integrates anti-corruption goals into nearly half of its partner country strategies, and funds civil society and ethical business initiatives. Sweden also benefits from an engaged and active media, which has been instrumental in exposing foreign bribery cases, bolstered by strikingly transparent and open information frameworks and robust protections for journalism. Additionally, Sweden has significantly enhanced its whistleblower protection framework with the adoption of new legislation in 2021, in line with EU and OECD standards.

The Working Group adopted the report on Sweden on 12 December 2024. The report is part of the Working Group’s fourth phase of monitoring, launched in 2016. Phase 4 looks at the evaluated country’s particular challenges and positive achievements. It also explores issues such as detection, enforcement, corporate liability, and international co-operation, as well as unresolved issues from prior reports. Pages 68-73 of the report contain the Working Group’s recommendations to Sweden. Due to the longstanding nature of the Working Group’s concerns, Sweden will report back orally in June and December 2025 on progress against high-priority recommendations, in particular in the context of the Legislative Inquiry.

Sweden will then report to the Working Group in two years (i.e., December 2026) on its implementation of all recommendations and its enforcement efforts.

For further information, journalists are invited to contact the OECD Media Office.

For more information on Sweden’s work to fight corruption, please visit the country web page.

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