NJORD Law Firm > Copenhagen, Denmark > Firm Profile

NJORD Law Firm

Denmark > EU, competition and public procurement Tier 1

Best known for its expertise in advising on dominant undertakings, NJORD Law Firm also handles rebate schemes and selective distribution issues. The team has particular expertise within the pharmaceuticals and medical devices industries, advising major clients on the full spectrum of issues relating to competition and EU law, as well as advising on large public contracts and litigation. Practice head Thomas Ryhl maintains a prominent reputation as a litigator of pharmaceuticals, competition and public procurement cases.

Practice head(s):

Thomas Ryhl


‘Deep knowledge, skill set, local knowledge, German lawyers also available in Denmark.’

‘I have mostly worked with Thomas Ryhl and I’m impressed with his knowledge, competence and capabilities to find a solid solution.’

Key clients


Smith & Nephew

Galenica Group




KeyLoop (formerly CDK)



Ferring Pharmaceuticals

Work highlights

  • Acting as lead counsel for Novartis Pharma & Ferring Pharmaceuticals in Europe-wide litigation against parallel importers; a number of cases on the new rules (Falsified Medicines Directive) now before the CJEU.
  • Acting as lead counsel for a consortium of 1,700 major global institutional investors in the largest claim ever filed in Denmark, seeking more than €2.3bn in damages from Novo Nordisk A/S for violations of the Market Abuse Regulation.
  • Advising Coloplast International on all complex EU competition law matters and the interplay with the EU procurement rules on a pan-European level.

Denmark > Dispute resolution Tier 3

NJORD Law Firm specialises in multi-party, complex litigation within a variety of legal areas spanning insurance law, shareholder actions and securities law. The group is also strong in administrative law, handling cases before administrative tribunals as well as defending municipalities and private companies and acting on behalf of the European Commission in CJEU cases against the Kingdom of Denmark. Thomas Ryhl and Jeppe Brogaard Clausen jointly head up the practice. Other names to note are transport and shipping specialist Ulla Fabricius and tax expert Robert Mikelsons.

Practice head(s):

Thomas Ryhl; Jeppe Brogaard Clausen

Other key lawyers:

Ulla Fabricius; Robert Mikelsons


‘Very knowledgeable in Transport and Insurance Law.’

Key clients


Louis Vuitton

Ferring Pharmaceuticals

J. Lauritzen A/S


Philips HealthTech

IF Skadeforsikring

Codan (RSA)

Bring Trucking (Posten Norge)

Omni Bridgeway (formerly IMF Bentham Group)

Novartis Pharma

Danish Ministry of Justice/Danish Parliament

Work highlights

  • Representing Novartis Pharma & Ferring Pharmaceuticals on Europe-wide litigation against parallel importers.
  • Representing Allianz Invest and 1700 other large institutional investors in the largest claim ever filed in Denmark, seeking more than €2.3bn in damages from Novo Nordisk A/S for violations of the Market Abuse Regulation.
  • Representing Bring in Jetzi vs Bring, an EU landmark case on international road transports against a coalition of European trade unions.

Denmark > Energy Tier 3

NJORD Law Firm focuses on developers within the energy sector, primarily advising international companies on cross-border issues. The practice also advises on transactions within the renewable energy sector, with particular expertise in solar energy and wind power. Thomas Rhyl is noted for his regulatory expertise.

Other key lawyers:

Key clients





Envision Energy

Belectric GmbH





Denmark > Information technology Tier 3

Led by Anders Wernblad , NJORD Law Firm‘s IT and telecoms team has extensive expertise in the intersection of IT and public law, handling large IT procurement projects in Denmark. The group works closely with its IP department and advises on issues concerning data protection, data processing and compliance. E-commerce mandates, ASP services and software licenses are other areas of expertise for the team.

Practice head(s):

Anders Wernblad


‘There is a sharp and thorough quality in Anders Wernblad’s legal opinions, which makes them highly reliable and valuable in difficult negotiations.’

‘They are house-lawyers. They know me and my partners inner most thoughts and aspirations with the business and related private matters.’

‘We have very close contacts and they they know our business inside out.’

Key clients

Procon Solution A/S

Adapt A/S

Boligsiden A/S

Conxion A/S

Luxplus ApS

Arbit Cyber Defence Systems ApS

Cookie Information A/S

NutraQ ApS

Signicat AS

Creditro A/S

Denmark > Insolvency Tier 3

NJORD Law Firm leverages its international network to advise on local and foreign insolvency mandates. The team acts on behalf of foreign creditors and has significant experience in managing assets abroad. Anders Hammer Hansen leads the team, which is also instructed by Danish banks and financial institutions as well as several trade unions.

Practice head(s):

Anders Hammer Hansen

Other key lawyers:

Malene Eigtved; Jørgen Erik Frandsen; Torben Krath


‘NJORD is a very versatile company where clients will meet lawyers who can help with most of their everyday legal issues.’

‘Torben Krath is a very skilled and pleasant colleague to work with.’

‘The team is efficient, likable and is excellent at coming up with commercial solutions.’

‘Anders Hammer is an excellent leader and knows how to bring the team up to speed.’

Key clients

Jyske Bank

Jyske Finans




Denmark > Media and entertainment Tier 3

NJORD Law Firm‘s media, sports and entertainment team has carved out a niche in the area of illegal file sharing, assisting film producers and other IP rights holders with protecting copyrighted material. Practice head Jeppe Brogaard Clausen has extensive experience in international IP issues, litigation and enforcement matters as well as counterfeit and passing off cases.

Practice head(s):

Jeppe Brogaard Clausen

Key clients


HBO (Home Box Office Ltd and HBO Nordic)

Resultmaker A/S

Copyright Management Services Ltd

Rovio Entertainment Oy

Philips Denmark A/S

Work highlights

  • Represented CMS in a case of illegal file sharing with a number of domestic and international rights holders against two of the largest internet service providers in Denmark.
  • Represented CMS and a large number of film producers in more than 100 successful cases regarding information injunctions against the largest ISPs in Sweden.
  • Represented Zentropa in four successful cases regarding information injunctions against the largest ISPs in Sweden.

Denmark > Real estate and construction Tier 3

NJORD Law Firm provides an ‘excellent service,’ working in specialised sub-teams to handle transactions and leases as well as issues within the construction and social housing sectors. Practice head Christian Schwarz-Hansen frequently advises on the optimisation of portfolios, rent increases, due diligence and conflicts with tenants. On the construction side, the team has extensive expertise in both international construction and small-scale local construction projects.

Practice head(s):

Christian Schwarz-Hansen

Other key lawyers:

Erik Larsson; Bettina Erringsø


‘Quick, sharp and knowledgeable. Reliable support and excellent service offered. Definitely to be recommended.’

‘Christian Schwarz-Hansen has an incredible ability to listen to his clients, understand their needs and consult them properly and realistically. In case a pragmatic and understandable approach is required, he is a perfect choice. He is quick, sharp, very knowledgeable and definitely a reliable partner on legal journeys.’

‘Collaboration is always on the point, multi-language skills, professional working environment.’

‘Professional knowledge, meeting deadlines, great professionalism.’

‘We are located in Germany and worked together with Christian Schwarz-Hansen and had the advice from a very competent and knowledgeable lawyer about real estate issues in Denmark.’

Key clients

Aluflam Iinternational A/S

Arpe & Kjeldsholm A/S

Bertelsen & Scheving Arkitekter A/S

BHS Logistics

Boligselskabet Nordkysten



By og Bolig Administration A/S

Ceraco A/S

Christensen & Co. Arkitekter

Ekona A/S

Elisabeth Schwartz f. Tafdrups family foundation, and Ellen & Carl Tafdrups memorial trust

Eriksson Stilladser A/S


HPH Totalbyg A/S

KAJ O. Madsen A/S

KSE Group A/S

Municipality of Silkeborg

Nordbo Huse


Lycée Français Prins Henrik’s Property Foundation

Rasmus Friis A/S

RH Greve ApS

University College Absalon

University of Copenhagen

Work highlights

  • Assisted Danish transport company BHS Logistics with the development and lease of a new headquarters.
  • Acting as construction manager for Arpe & Kjeldsholm A/S regarding a part of a new urban living district called “Carlsberg Byen” on a former Carlsberg brewery site in the heart of Copenhagen.
  • Assisted CERACO with a turnkey contract for residential project development at Badehusvej in Aalborg.

Denmark > Shipping and transport Tier 3

NJORD Law Firm‘s maritime and transport practice focuses on logistics and road transport work as well as the offshore industry. The group holds a unique position advising and representing freight forwarders and haulage companies in matters relating to the EU Mobility Package, posting of drivers and all matters relating to ‘social dumping’. Ulla Fabricius heads up the practice, which also handles ship recycling and decommissioning work, pool agreements and complex logistics contracts.

Practice head(s):

Ulla Fabricius

Other key lawyers:

Key clients

Codan Forsikring A/S


Anders Nielsen & Co. A/S

DSV Group of companies

H.P. Therkelsen A/S

Bring Group of Companies

Johs. Rasmussen, Svebølle A/S

BHS Logistics A/S

SAL Heavy Lift

United Heavy Lift

Denmark > Tax Tier 3

NJORD Law Firm provides tax and VAT advice on cross-border transactions and international trade issues in the Nordics. The group is led by Robert Mikelsons , who has extensive experience in international tax and VAT claims before Danish courts, including the Supreme Court, and the European Court of Justice. The team is also adept at advising on corporate structures, restructurings and incentive programmes.

Practice head(s):

Robert Mikelsons

Other key lawyers:

René Lykke Wethelund; Niels Gade-Jacobson

Key clients

ABN Amro Group


United Chemi-CON

Ress Life Investments



Dansk Shell

Parken Sport and Entertainment

Bonnier Publications

Teknologisk Institut

Work highlights

  • Providing Liechtenstein Foundations with ongoing advice and negotiations with the Danish Tax Agency in order to be tax compliant in Denmark.
  • Advising Dansk Shell A/S on ongoing tax and VAT cases (valued at €16.8m) in the Danish Tax Courts.
  • Representing Danish Property Investment Funds in ongoing tax cases (valued at €15 m) in the Danish tax courts.

Denmark > Banking and finance Tier 4

Denmark > Employment Tier 4

NJORD Law Firm specialises in organisational restructurings that involve multiple Nordic jurisdictions, advising on mergers, the insourcing and outsourcing of work areas, acquisitions and sales of businesses, and union negotiations. Miriam Michaelsen leads the team that includes industrial and relations law specialist Anders Worsøe.

Practice head(s):

Miriam Michaelsen

Other key lawyers:

Key clients

LSG Sky Chefs Group

Kramp Groep B.V.

Gerry Weber Denmark ApS & Gerry Weber Group, Germany

REMS GmbH & Co. KG and their Danish subsidiary REMS Scandinavia A/S

Star Inc. (former Cogniance, Inc.)

Sennheiser HQ and Sennheiser Nordic A/S

Advanced Energy Industries and Danish subsidiary LumaSense Technologies A/S

Teknos OY and Danish subsidiary Teknos A/S

The Danish Road Traffic Authority

Denmark > Intellectual property Tier 4

Jeppe Brogaard Clausen and Thomas Ryhl jointly lead the practice at NJORD Law Firm which is split into two teams: the intellectual property team and the life sciences and healthcare group. The IP team handles the full range of issues, including IP prosecutions, litigation and contracts; Clausen has a strong profile in counterfeit and passing off cases and is adept at handling cross-border mandates. On the life sciences team, Ryhl is an EU and pharmaceuticals law specialist.

Practice head(s):

Jeppe Brogaard Clausen; Thomas Ryhl

Other key lawyers:

Frank Jørgensen


‘Extremely strong expertise in the area of IP and pharma – both Danish & EU law. Excellent value for money. Pragmatic advice.’

Key clients

Estrella Maarud AS – part of Intersnack

The Whole Company

Novartis Pharma



Coty – including Davidoff, Calvin Klein, Marc Jacobs etc.

Siemens Healthcare (Siemens Healtineers)

Ferring Pharmaceuticals

Astellas Pharma

Smith & Nephew

Philips HealthTech

Allergan (BOTOX)




Work highlights

  • Representing Novartis Pharma AG in Europe-wide litigation against parallel importers (and national regulatory bodies), with a number of cases referred to the European Court of Justice (CJEU).
  • Advising Ferring in cases against national regulatory bodies on the illegal acceptance of generic, non-approved pharmaceuticals for use in hospitals.
  • Assisting Siemens Healthineers (Siemens Medico) with the legal audit of policies, contracts, etc. in seven Nordic jurisdictions, including regulatory compliance issues.

Denmark > Commercial, corporate and M&A Tier 5

NJORD Law Firm leverages its six offices across the Nordic region to advise both Danish and international clients on cross-border transactions. Private equity and venture capital investments are growing areas of focus for the team as well as general corporate counselling. Practice head René Lykke Wethelund specialises in management buy-ins and buy-outs.

Practice head(s):

René Lykke Wethelund

Other key lawyers:

Jens Christian Dreyer; Lars Lokdam


‘Wide knowledge and services across all business activities, from board meetings to M&A activities.’

‘Personal and direct contact with relevant individuals, approachable and service-oriented.’

Key clients


AP Pension

Bauhaus Danmark A/S

Forenede Service


Boehringer Ingelheim Danmark A/S

Vailant A/S

Petworld A/S

Comcare A/S

HandiMobil A/S

Enghouse Systems

CompuGroup Medical

Karl Storz Endoskopi A/S

Lind Invest ApS

Aarhus Airport A/S

Sodexo A/S

Reinh van Hauen ApS

Oooono A/S


One Peak

Global PayTech Ventures

Kramp Groep B.V.

Work highlights

  • Advised Petworld on its sale of all operational assets of its multi-channel business to German Fressnapf and Maxi Zoo.
  • Advised Luxemburg-based VC fund One Peak on its investment in Danish software company Keepit A/S.
  • Advised Ooono A/S on its purchase of all operating assets of WUSAA in a crowd-funded transaction, financed via a London-based crowd funding service provider.

The firm: NJORD Law Firm is a leading international full-service law firm with a strong presence in the Nordic and the Baltic Sea area with offices in Denmark, Estonia, Lithuania, and Latvia.

Its 200+ professionals provide legal services within all corporate and commercial law areas and adapt it to any market condition. About half of the world’s top 100 brands are among NJORD Law Firm’s clients.

A large number of natives employed from Norway, Sweden, Finland, Germany and the US working at the Copenhagen office give NJORD Law Firm access to a wide range of jurisdictions, and the firm continues to add new nationalities to its team. Currently, they think, talk, and co-operate in more than 25 languages – 17 of which are spoken as the native tongue.

Whether the assignment is a Danish transfer of a business or a Pan-Nordic trade mark protection, NJORD’s lawyers bring openness, regional scope, and international knowledge and vision into play.

In summary, NJORD Law Firm offers local know-how, a Nordic approach, and global experience.

Areas of practice: At NJORD, the lawyers combine profound professional expertise with distinct and direct counselling – in plain language – providing value-adding advice to its client’s business. In addition, a number of partners bring solid business experience from in-house positions in large companies.

Due to NJORD’s lawyers’ strong business sense and extensive expertise in working cross-border, they assist clients in navigating the pitfalls of both Danish, Nordic, and international law. This means their clients often only need to seek legal advice in one place.

In addition, NJORD’s specialists have set up several multidisciplinary innovative teams working across the departments – e.g. the drone and robotics group delivering innovative and solution-oriented advice within all technological specialities, and the bilingual German Nordic legal desk, which is the most ambitious and experienced in Denmark and the Nordic region.

Banking and Finance Kim Høibye
Corporate/M&A Lars Lokdam
Corporate/M&A Henrik Lyhne
Corporate/M&A Jens Christian Dreyer
Corporate/M&A René Lykke Wethelund
Dispute resolution Ulla Fabricius
Employment and labour Miriam Michaelsen
Employment and labour Anders Worsøe
German Nordic legal Stefan Reinel
EU & Competition, Maritime & Transport, Procurement & Public Authorities, and Life Sciences and Healthtech Thomas Ryhl
Intellectual property Jeppe Brogaard Clausen
Intellectual property Peter Gustav Olson
Insolvency and restructuring Anders Hammer Hansen
IT Anders Wernblad
Maritime and transport Ulla Fabricius
Private equity René Lykke Wethelund
Private equity Robert Mikelsons
Real estate and construction Erik Larsson
Real estate and construction Christian Schwarz-Hansen
Tax Robert Mikelsons
Data Protection Nis Peter Dall
Corporate/M&A Rune Tarnø
Jeppe Brogaard Clausen photoMr Jeppe Brogaard ClausenJeppe Brogaard Clausen is a specialist in intellectual property law. For more…
Nis Peter Dall photoMr Nis Peter DallNis Peter Dall is primarily engaged in data protection law, IT law…
Jens Christian Dreyer photoMr Jens Christian DreyerJens Christian Dreyer is engaged in general commercial law and is rendering…
Ulla Fabricius photoMrs Ulla FabriciusFor many years, Ulla Fabricius has advised both national and international transport…
Jørgen Erik Frandsen photoMr Jørgen Erik FrandsenJørgen Erik Frandsen is primarily engaged in counselling of financial businesses and…
Karsten Gudmand-Høyer photoMr Karsten Gudmand-HøyerKarsten Gudmand-Høyer is one of the leading experts within the field of…
Anders Hammer Hansen photoMr Anders Hammer HansenAnders Hammer Hansen specialises in insolvency law, including insolvency and restructuring. He…
Kim Høibye photoMr Kim HøibyeKim Høibye has special experience in advising Danish and international companies in…
Therèse Kemp photoMs Therèse KempTherèse Kemp’s day-to-day work consists in the handling of successions, the drafting…
Erik Larsson photoMr Erik LarssonErik Larsson specialises in construction law, real estate, guarantees, contract law, social…
Lars Lokdam photoMr Lars LokdamLars Lokdam specialises in the purchase and sale of enterprises, and he…
Henrik Lyhne photoMr Henrik LyhneHenrik Lyhne specialises in business law and primarily deals with company law…
René Lykke Wethelund photoMr René Lykke WethelundPartner René Lykke Wethelund is a corporate and M&A specialist with a…
Miriam Michaelsen photoMrs Miriam MichaelsenPartner Miriam Michaelsen, head of the Employment Law team, is specialised in…
Robert Mikelsons photoMr Robert MikelsonsRobert Mikelsons is the head of NJORD’s tax specialist group. He gives…
Peter Gustav Olson photoMr Peter Gustav OlsonPeter Gustav Olson specialises in EU trademarks, EU designs, and domain names.…
Stefan Reinel photoMr Stefan ReinelStefan Reinel specialises in international and German legal matters and has advised…
Thomas Ryhl photoMr Thomas RyhlThomas Ryhl is a committed and very knowledgeable attorney. He takes pride…
Jakob Stilling photoMr Jakob StillingJakob Stilling is an authorized administrator with the bankruptcy division of the…
Anders Wernblad photoMr Anders WernbladAnders Wernblad has a great knowledge of the legal sector and legal…
Anders Worsøe photoMr Anders WorsøeAnders Worsøe is well-versed in multiple legal disciplines and mostly with an…
Number of lawyers : 107
Other offices : Aarhus
Other Offices : Silkeborg
Other offices : Riga
Other offices : Tallinn
Other offices : Vilnius
Other offices : Roskilde


Diversity is the essence of the atmosphere at NJORD Law Firm. 

We think, speak and collaborate in more than 25 languages. We see the diversity of our employees as a strength – both in terms of career, life experience, nationality, religion, and sexuality. This makes us a diverse, international and modern law firm. 


We are fighting to leave concrete marks through our work. 

We are members of the United Nations Global Compact and have, among other things, based NJORDs ethical guidelines on their ten principles, which are embodied in the UNs 17 Sustainable Development Goals. The ten principles include social accountability based on internationally agreed conventions on labour and human rights, the environment, and anti-corruption. In addition, we are a member of the Danish Bar and Law Society and have joined the Association of Danish Law Firms advokatKODEKS (lawyers code). 

We fight for those whose voices are not heard. 

With the law behind us, we take on responsibility by fighting also for those whose voice is not being heard. We do this, for instance, in cases regarding digital violations. We supported the establishment of the association Digitalt Ansvar (Digital Responsibility) (DIGA), which we largely assist with pro bono work. The massive total effort by several parties against digital violations has created an increased awareness of the problem in society. We see a tendency towards a change in digital behaviour, increased maximum penalties for digital sexual violations, and an increased focus from the police on digital violations. 

NJORD Law Firm, represented by Attorney and Partner Miriam Michaelsen, received the Association of Danish Law Firms advokatKODEKS award 2018 for its efforts against digital offences. NJORD received the award for its focused efforts to create fair solutions for its clients and for those whose voice is not being heard. 

We are CO2 conscious 

NJORD Law Firm was on 1 January 2019 certified CO2-neutral, as one of the first law firms in Denmark. 

At NJORD, consideration and accountability are integrated into the small and simple choices of everyday life. We reduce travel activity and CO2 emissions by hosting online face-to-face meetings in digital meeting rooms. In addition, we have a number of office bicycles, which we use for meetings in the local area to minimize short-distance driving. Several departments have been digitized to minimize printing. 

Ulla Fabricius, Attorney at Law, Partner

The Legal 500 Hall of Fame highlights individuals who have received constant praise by their clients for continued excellence.Attorney at law and partner Ulla Fabricius talks about her successful work as a lawyer and predicts the biggest challenge for clients over the next year.

What has been your greatest achievement, in a professional and personal capability?

As a female lawyer specialized within Shipping- and Transport law, I am proud to have made my way to become a highly trusted and recognized legal adviser for many clients in the industry. I take particular pride in having worked closely together with the industry to obtain the changes in the regulation on driving and rest time, which were so essential for the industry. On a personal level, I am happy having been able to have a family and raise our wonderful children besides having a career.

What do you do differently from your peers in the industry?

I have an in-depth knowledge and understanding of my client’s business and situation for which reason I have a very good background for reaching the best possible solution to legal issues presented to me by clients.

I have drafted the Danish legal commentary to the CMR Convention, which gives me a very solid basis for advising on CMR matters including logistics and project cargo.

What advice would you give to your younger self?

Do not worry so much – you will be able to become a trusted adviser within your field.

Can you give me a practical example of how you helped a client add value to the business?

I have advised a client on how to negotiate a balanced logistics contract which resulted in the client winning the contract because they could see possibilities where most of their competitors saw obstacles.

Within your sector, what do you think will be the biggest challenge for clients over the next 12 months?

Competition is still fierce. The upcoming new EU regulation on, amongst others, Cabotage is expected to create new challenges as it is essential for the transport companies to find hauliers and drivers to carry cargo within Europe.

Thomas Rhyl, Attorney at Law, Partner

The Legal 500 Hall of Fame highlights individuals who have received constant praise by their clients for continued excellence.Attorney at law and partner Thomas Ryhl talks about his successful work as a lawyer and predicts the biggest challenge for clients over the next year.

What has been your greatest achievement, in a professional and personal capability?

To win all the cases I’ve litigated before the Court of Justice of the European Union – whether representing the EU Commission, global corporations, or private individuals – has been a welcome reward for the countless hours spent on specializing and keeping up to date in the dynamic field of EU law. Keeping ahead in a field where the finest lawyers from all of Europe compete requires a constant and dynamic interaction with both clients, scholars, and my own team, and to build such relationships has been very rewarding, in each and every case fought over the years. On a personal level, it has been a great pleasure to see pro bono work being rewarded with the Grand Chamber of the CJEU overturning Danish immigration law in 2016, reversing more than 12 years practice of illegally refusing children of migrant workers to live with their parents: All refusals have now been reversed, and the families reunited.

What do you do differently from your peers in the industry?

Although I have to delegate work to members of my team, I take pride in knowing and understanding every aspect of my clients’ business and situation, keeping in constant close touch. My clients are my friends, and quite a few of them have become personal friends as well. These close relationships constantly provides me with new insights and in-depth knowledge, making me well-prepared to deal with all kinds of legal problems, as a generalist and not just as an extremely focused specialist.

What advice would you give to your younger self?

To have faith in the fact that dedication, solid expertise, and professionalism will win you the best clients in the longer run: Networks aren’t the only key to winning business. And to specialize early on in an area of law where you are not limited to a small jurisdiction like Denmark in your work as a lawyer: Mastering EU competition law, you can help clients all over Europe and the world.

Can you give me a practical example of how you helped a client add value to the business?

By limiting parallel imports of pharmaceuticals. Persuading the CJEU to overturn a judgment of the German Supreme Court and ruling against the EU Commission, I succeeded in reminding courts around Europe of the importance of protecting the rights of trademark owners, allowing original manufacturers of pharmaceuticals and medical devices to limit the detrimental re-packaging and re-branding of parallel imported products. The whole industry eagerly welcomed the 2016 judgment.

Within your sector, what do you think will be the biggest challenge for clients over the next 12 months?

To ensure that the competition authorities, as well as the regulatory bodies of the different Member States, do not become omnipotent, but are constantly reminded to respect the rule of law and the rights and privileges of undertakings. Aiming to please those currently in power, rather than to ensure a correct implementation of EU law, seems to be increasingly important to many enforcers in both the Nordics and around Europe.