On 29 May 2026, an executive order was issued which implements parts of the first 15 EU sanctions packages against Russia and Belarus, covering trade, energy, transport, and financial activities. The executive order became effective on 31 May 2026. This supplements the implementation of certain parts of the first 14 sanctions packages which already apply in Greenland within the areas of competence that have been taken over from Denmark. The 16th to 20th sanctions packages against Russia have not yet been implemented, adding to the complexity of understanding the exact scope of the application in Greenland of the EU sanctions regime against Russia and Belarus.
The latest sanctions measures are set out in Executive Order no. 497 of 29 May 2026 for Greenland on restrictive measures against Russia and Belarus within the area of the Ministry of Industry, Business and Financial Affairs (the “Executive Order”), available here.
The Greenlandic Executive Order no. 47 of 20 November 2024 on the accession of the restrictive measures against Russia and others, as adopted by the European Union (EU), implementing parts of the first 14 sanctions packages is available here.
The sanctions adopted with the new Executive Order are wide-ranging and introduce a number of new prohibitions in Greenland. This includes rules relating to sale of tankers for the transport of crude oil or petroleum products, as well as prohibitions against providing technical assistance, brokering services, financing, or financial assistance related to the trading, brokering, or transport to third countries of Russian origin crude oil or petroleum products. A ban also applies in relation to sale to Russian persons and legal entities of certain maritime navigation goods and technology, including navigation equipment and radio-communication equipment.
Further, a prohibition is implemented on the export of certain goods and technology suited for use in aviation or the space industry, as well as jet fuel and fuel additives to persons or entities in Russia or for use in Russia. The sanctions include a related service ban.
Moreover, an export ban is introduced on goods and technology suited for use in oil refining and liquefaction of natural gas and an import ban is introduced relating to Russia-origin liquified gas.
A new executive order regarding export control of dual-use products (the “Executive Order on Dual-Use”) is expected to be issued soon. The draft executive order for Greenland on control of export of dual-use products has been sent out for consultation and is available here.
The Executive Order on Dual-Use amends the Greenlandic export control regime by replacing the existing Greenlandic dual-use control list with a reference to Annex I to Regulation (EU) 2021/821 of 20 May 2021 setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items. Consequently, when Annex I to the Regulation is updated, those updates will also apply to the Greenlandic export control regime. This ensures that the Greenlandic control list remains aligned with the EU control list at all times.
Another significant area where the legal landscape is changing is foreign direct investments (“FDI”). On 10 November 2025, a proposal for a Greenlandic FDI act was presented. The proposal required screening of foreign direct investments where the foreign investor would obtain at least 25% of the shares, voting rights, or similar control in Greenlandic entities within particularly sensitive sectors, including:
Following cabinet changes in April 2026, the proposal was postponed. A revised FDI proposal is expected to be presented during the fall of 2026. It remains uncertain which amendments, if any, will be introduced compared to the previous proposal.
Gorrissen Federspiel closely follows the developments within sanctions, export controls and FDI and can assist with interpretation of and compliance with applicable law as well as the implementation of measures to ensure that such regulations are observed. If you have any questions, please feel free to contact a member of our Compliance & Sustainability team.
For more information on the previous EU sanctions packages, please see Gorrissen Federspiel’s newsletters of 26 April 2026, 24 October 2025, 23 July 2025, 21 May 2025, 25 February 2025, 19 December 2024, 25 June 2024, 27 February 2024, 19 December 2023, 26 June 2023, 27 February 2023, 19 December 2022, 7 October 2022, 8 June 2022, 11 April 2022, 16 March 2022, 10 March 2022, 2 March 2022, 28 February 2022, and 24 February 2022.