In accordance with Section 121, Paragraph 1 of the Law on International and National Sanctions of the Republic of Latvia (Sanctions Law), the Financial Intelligence Unit of Latvia (FIU) is the competent authority in the matters of implementation of international and national sanctions insofar as laws and regulations do not provide otherwise.
The informational material available in this section has been prepared by the FIU to help all persons comply with the international, European Union (EU) and Latvian laws and regulations governing sanctions (sanctions legislation). The informational material reflects the FIU's opinion about the best practices in relation to the questions received.
The general explanations provided in the informational material are neither legally binding, nor are they to be considered a statement or legal advice provided by the FIU. The explanations are based on the analysis of the legal provisions of sanctions legislation and on the guidelines provided by the Council of the EU, the European Commission and other institutions. These guidelines may change periodically due to changes in the legislation or new case-law of the EU Court of Justice, thus affecting also the explanations provided by the FIU. It should be noted that in accordance with the applicable legislation the FIU is not authorised to perform an official interpretation of legal provisions.
The explanations and recommendations provided in this section are intended as general guidelines. With respect to the obligation for all persons to comply with and implement international and national sanctions set out in Section 2, Paragraph 2 of the Sanctions Law, the FIU invites each person to independently apply the provisions of sanctions legislation, taking into consideration the actual circumstances of each individual situation.
If necessary, we invite you to contact the FIU by either submitting an application in accordance with the procedure specified in the Law on Submissions , writing to the email address: sankcijas@fid.gov.lv or by calling the phone number +371 67044430. Detailed contact information and information on methods of communication are available here.
We draw your attention to the fact that the informational material is periodically reviewed and updated. If an update is made in connection with one of the questions, or a section is supplemented with a new question, the information about the update will be mentioned under the respective question.
Sanctions are restrictions or prohibitions established in accordance with international public law, European Union regulations, or national legislation. They are imposed by international organizations or individual states. The purpose of sanctions is to restore peace and security in a region or to prevent threats to international peace and security. Currently, the European Union has almost 50 different sanctions regimes in place. Some of these have been established by the United Nations Security Council, while others have been independently imposed by the European Union.
Sanctions can be classified into the following main types:
Targeted Financial Sanctions:
The aforementioned essentially means that it is prohibited to directly or indirectly engage in any transactions with natural or legal persons included in the European Union’s targeted financial sanctions lists, as well as with legal persons that are directly or indirectly owned or controlled 50% or more by individuals or entities included in the European Union’s sanctions lists.
Sectoral sanctions are generally sanctions imposed on specific goods and services, prohibiting the provision of services and the import, export, or transit of goods. In response to Russia’s full-scale military invasion of Ukraine, the European Union has imposed unprecedented types of sectoral sanctions against Russia and Belarus (including, but not limited to, prohibitions on holding certain positions, providing legal and accounting services, accepting deposits exceeding EUR 100,000, awarding or continuing to execute public procurement contracts with certain categories of persons, and imposing price caps on petroleum products, among others).
1Council Regulation (EU) No 269/2014 (17 March 2014), concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty, and independence of Ukraine, Article 2; Council Regulation (EC) No 765/2006 (18 May 2006), concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, Article 2.
The main restrictive measures against Russia are defined in the following Council Regulations:
Council Regulation (EU) No 269/2014 (17 March 2014), concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty, and independence of Ukraine (Regulation No 269/2014) ;
Council Regulation (EU) No 833/2014 (31 July 2014), concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (Regulation No 833/2014).
The main restrictive measures against Belarus are defined in:
Council Regulation (EC) No 765/2006 (18 May 2006), concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine(Regulation No 765/2006).
Sanctions are also imposed on certain citizens of Belarus under Regulation No. 269/2014.
NB: The FIU recommends consulting the most recent consolidated versions of the relevant Regulations.
The European Union Sanctions Map provides information on sanctions applied by the EU against specific countries, natural and legal persons, sectoral restrictions, as well as the legal acts in which these measures are established.
The European Union sanctions regulatory framework provides narrowly defined exemptions, in which sanctions do not need to be applied in specific cases, for example, if a contract concluded prior to the imposition of the relevant sanctions is performed within the time limits set out in the sanctions legislation.
Similarly, the European Union sanctions regulatory framework also provides for certain narrowly defined derogations from sanctions, allowing an otherwise prohibited activity to be carried out if authorisation has been obtained from the competent national authority (in Latvia – the FIU).
According to Article 2, Clause 2 of the International and the Republic of Latvia’s National Sanctions Law (Sanctions Law), all persons are obligated to comply with and implement international and national sanctions.
This includes all natural persons residing within the jurisdiction of the European Union (including those who are not EU citizens but reside within EU territory) and all legal persons.
The FIU emphasizes that every person must take necessary actions to ensure compliance with international and national sanctions. This includes ensuring that cooperation with the specific individual does not violate sectoral sanctions (sanctions imposed on specific goods or services, prohibiting the provision of services or the import or export of certain goods) or targeted financial sanctions (sanctions that prohibit, directly or indirectly, the making available of funds or economic resources to specific persons).
Yes. While present within the territory of the European Union, the European Union sanctions regulatory framework must be complied with by all persons, irrespective of their nationality, including third-country nationals who have been granted a temporary residence permit in a Member State (for example, in Latvia).
With regard to transactions and activities outside the territory of the European Union, the application of the sanctions regulatory framework may differ. For nationals of the Member States, sanctions are binding also outside the territory of the European Union, whereas for third-country nationals, including those holding a temporary residence permit in a Member State, sanctions are generally not directly binding in respect of transactions and activities outside the European Union, unless another ground for applicability can be identified, for example where the transaction or activity takes place wholly or partly within the European Union.¹
Attention is drawn to the fact that a person who has breached restrictive measures binding upon them may be held liable, including criminal liability.
¹ For example, Article 17 of Regulation No 269/2014, Article 13 of Regulation No 833/2014, and Article 10 of Regulation No 765/2006.
No. Generally, the FIU does not provide individually addressed confirmations regarding the application of sanctions to specific persons, transactions or actions. Sanctions Law does not impose an obligation on the FIU to:
At the same time, the FIU, as the national competent authority of Latvia in the field of sanctions implementation, provides methodological explanations and support on issues related to the application of sanctions. The FIU provides explanations, for example, where:
It should be taken into account that responsibility for compliance with sanctions, as well as for assessing the compliance of a specific transaction or action, remains with the person concerned. This applies to both targeted financial sanctions and sectoral sanctions and includes the obligation to carry out due diligence based on the available information and the applicable regulatory framework.
To ensure effective compliance with sanctions, both in the context of targeted financial sanctions and sectoral sanctions, each person is responsible for conducting sanctions risk management. Sanctions risk refers to the potential threats and vulnerabilities that may lead to a sanctions breach. This means that, as a primary step, due diligence must be carried out with respect to the transaction partners, the persons involved (e.g., manufacturers, suppliers, intermediaries, credit institutions), as well as the transaction or activity itself, including an assessment of whether:
¹ Article 1(i) of Regulation (EU) No 269/2014.
² Article 1(j) of Regulation (EU) No 269/2014.
All up-to-date information on persons included in sanctions lists can be found on the FIU Latvia website under the sections “Sanctioned persons” and “Search on sanctions lists”. It should be taken into account that the Sanctions Search tool contains information only on persons directly included in sanctions lists and does not include information on legal persons that are not directly listed but are owned or controlled by listed persons.
Additional sources that may be used for verification include:
The section “Frozen assets” on the official FIU Latvia website provides detailed information on funds and economic resources frozen in Latvia. This list also includes all legal persons known to Latvian authorities that are owned or controlled by persons included in sanctions lists.
During the verification process, it is necessary to compile the information obtained regarding the transaction partner and the transaction itself, in order to maintain a sufficient body of evidence demonstrating that the due diligence check has been carried out. The person must then assess whether the potential transaction involves risks of sanctions circumvention or violation — for example, where the transaction partner has an unreasonably complex ownership structure, information about the ownership is not available in public registers, or the management or supervisory board of the transaction partner includes a person subject to sanctions, among other indicators.
The level of detail required in conducting due diligence depends on the specific risks associated with the transaction, which are influenced by various factors. For example, transactions involving high-risk countries¹, as well as Russia and Belarus, are considered to carry very high risks. In the context of sectoral sanctions, elevated risks exist where a transaction involves goods, technologies, or services subject to sanctions (including cases where the transaction takes place within the European Union).
¹ High-risk sanctions jurisdictions are countries that have been identified as posing increased sanctions-evasion risks based, among other factors, on reports of suspicious transactions submitted to the FIU, information provided by the State Revenue Service Customs Board regarding transactions exhibiting indicators of sanctions circumvention, as well as information compiled by the European Union, European Union Member State competent authorities, and other foreign competent authorities. High-risk jurisdictions include, among others, the Member States of the Eurasian Economic Union (Armenia, Kazakhstan, and Kyrgyzstan), countries of the Commonwealth of Independent States (Azerbaijan, Tajikistan, Uzbekistan), as well as other countries that do not impose sanctions against Russia (the United Arab Emirates, Georgia, India, China—including Hong Kong—Mongolia, Serbia, Thailand, and Turkey).
Enhanced due diligence of transaction counterparties must be conducted both for direct transaction counterparties and for merchants indirectly involved in transactions, including consignors, consignees, storage providers, end users or manufacturers of goods, final recipients of services, payers or recipients of payments. The results of enhanced due diligence of transaction counterparties must be documented and retained.
In enhanced transaction due diligence, transaction documents and information regarding the transaction are obtained, including transport documents, customs declarations, information on the transportation route of goods, and modes of transport. In transactions related to the import of goods, verification of the credibility of the origin of goods is carried out by obtaining and verifying information and documents substantiating the origin of goods. In transactions related to the export of goods, verification of the end user of goods is carried out by obtaining and verifying information on the end user and end use of the goods. The results of enhanced due diligence must be documented and retained.
Information about risk indicators related to transactions or transaction partners is available in the FIU-developed guidelines “Sanctions risk management for business in heightened-risk countries” (available in Latvian language). Although the guidelines primarily address EU sanctions against Russia and Belarus, they are also applicable in broader contexts involving other sanctions risks.
The guidelines explain:
Additional information about sanctions evasion indicators is available in the FIU’s material “Indicators of Sectoral and Targeted Financial Sanction Evasion”.
The FIU Latvia website provides several guidelines and explanatory materials in the area of sanctions.
The European Commission has developed the “Consolidated FAQs on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014”, which are regularly updated.
The European Commission has also established the EU Sanctions Support Hub, which provides assistance to small and medium-sized enterprises in ensuring compliance with EU sanctions, including explanations on the application of sanctions, practical support in identifying risks, and assistance in strengthening sanctions compliance.
The FIU regularly provides methodological support and organises training in the field of sanctions. Information on such activities is published on the FIU Latvia website under the “News” section, as well as on the FIU’s social media pages (Facebook and LinkedIn).
If it is established that the name and surname of a transaction partner match the name and surname of a person included in a sanctions list, the FIU recommends obtaining additional information about the individual by searching publicly available registers and databases. During this process, it is advisable to compare the personal identification number, year and date of birth, place of birth (country and city), as well as any other publicly available information that may help identify the relevant individual. Likewise, if the person’s country of birth is, for example, Russia, special attention should be paid to the spelling of the name and surname, as it may vary depending on the language or cultural conventions applicable in that country.
According to Article 2, first paragraph of the Sanctions Law, sanctions imposed by a Member State of the European Union or a member state of the North Atlantic Treaty Organization (NATO), including sanctions administered by the U.S. Office of Foreign Assets Control (OFAC), are applicable only in the cases specified in the Sanctions Law, for example, in the cases set out in Sections 11.1–11.3 thereof. In addition, sanctions administered by OFAC are applied by financial market participants in certain circumstances. Accordingly, as a general rule, persons in Latvia are not required to comply with OFAC sanctions, except in cases expressly provided for by law. At the same time, making or receiving payments to or from persons subject to OFAC sanctions may be burdensome or even impossible. Furthermore, the fact that a person is subject to OFAC sanctions or sanctions imposed by another NATO member state in connection with its support for Russia’s war against Ukraine should be taken into account when assessing the sanctions risks associated with cooperation with that person.
According to Article 121, first paragraph of the Sanctions Law, the FIU is the competent institution for matters relating to the implementation of international and national sanctions, unless otherwise provided for by law. Therefore, the FIU does not have competence to assess the application of sanctions imposed by a NATO member state (including OFAC sanctions).
According to Article 18, second paragraph of the Sanctions Law, administrative penalties apply only to minor violations—such as when sanctioned goods are purchased, sold, or moved across the national border of Latvia, or when intermediary services, technical assistance, or related services are provided for such goods — if the value does not exceed 10,000 euros.
Possible fines are up to 10,000 euros for natural persons and up to 30,000 euros for legal persons.
At the same time, the FIU highlights that violations involving targeted financial sanctions (e.g., making funds or economic resources available to sanctioned persons), prohibited services, or dual-use and strategically significant goods may result in criminal liability under Article 84 of the Criminal Law, regardless of the value of the goods or services.
Persons subject to the supervision of the supervisory authorities referred to in Article 13 of the Sanctions Law have the obligation, in accordance with the Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing, to immediately report to the FIU any suspicions of a breach or attempted breach of international or national sanctions, using the goAML system. Further information is available in the FIU’s guidelines “Reporting Suspicious Transactions and Refraining from Execution of Suspicious Transactions” (available in Latvian language).
In addition, any person is encouraged to report suspicions of a sanctions violation or attempted violation. Reports can be submitted in accordance with Article 17 of the Sanctions Law by emailing: pasts@fid.gov.lv. Relevant supporting documents should be attached.
In general, it is prohibited to carry euro banknotes to Russia or Belarus, however narrowly defined exemptions
exist when this is allowed.
According to Article 5i of Regulation No. 833/2014 and Article 1za of
Regulation No. 765/2006, it is prohibited to sell, supply, transfer, or export
euro banknotes (or the official currency of any EU Member State) to Russia
or Belarus or to any natural or legal person,
entity, or body in those states, including the governments or central banks of
Russia or Belarus, or for use therein.
This prohibition does not apply when the banknotes are necessary for the
personal use of natural persons travelling to Russia or Belarus, or of their immediate family members travelling with them,
or for official purposes such as diplomatic missions, consular posts,
international organisations, or support for democracy.
However, according to the case law of the Court of Justice of the European
Union, such an exemption must be interpreted narrowly and does not cover
broadly understood ‘personal needs’ such as medical expenses or personal
purchases, but only funds required for travel and subsistence expenses (for example,
food, transport tickets, short-term accommodation).
Cash intended for any other purposes may be detained or confiscated if a
sanctions violation is established.
In general, nationals of Russia are prohibited from
making deposits exceeding EUR 100,000.1 It should be noted that the
term ‘deposit’ under sanctions is broader and refers to any account balance.
More detailed information on deposits is provided in the European Commission’sguidelines ‘Consolidated FAQs on the implementation of Council Regulation No833/2014 and Council Regulation No 269/2014’, point 5 of section C.
At the same time, Regulation No. 833/2014 provides exemptions and derogations
that in specific cases allow deposits exceeding EUR 100,000.2
For example, according to Article 5b(3) of Regulation No. 833/2014, the prohibitions in paragraphs 1, 2, and 2a do not apply to nationals of a Member State, an EEA country, or Switzerland, or to natural persons holding a temporary or permanent residence permit in those states. Thus, if a national of Russia has been issued a temporary or permanent residence permit in an EU Member State, an EEA country, or Switzerland, the prohibition in Article 5b(1) of Regulation No. 833/2014 does not apply to them.
1This follows from Article 5b(1) of Regulation No. 833/2014, which prohibits the acceptance of any deposits from nationals of Russia or natural persons residing in Russia, from legal persons, entities, or bodies established in Russia, or from legal persons, entities, or bodies established outside the European Union in which more than 50% of the ownership rights are directly or indirectly held by nationals of Russia or natural persons residing in Russia, if the total value of deposits of the said natural or legal persons, entities, or bodies with one credit institution exceeds EUR 100,000.
2 Regulation No. 833/2014, Article 5b(3), Article 5c(1), and Article 5d(1).
Yes. Having an account with a bank included in a sanctions list constitutes a violation of European Union sanctions. This follows from Article 2 of Regulation No. 269/2014, which requires that the funds and economic resources of listed persons be frozen, and that no funds or economic resources be made available to such persons.
By maintaining an account with a credit institution that is included in a sanctions list, a person is effectively making funds available to the sanctioned entity—for example, by paying commission fees or other service charges—which is considered a sanctions violation.
The same applies in cases where a client holds or deposits funds with such a credit institution, including in the form of a deposit, savings account, or other similar arrangement. Any form of holding funds or receiving services from a credit institution listed under sanctions means that funds are being made available to the sanctioned entity, and such conduct qualifies as a sanctions violation.
The fact that the account or deposit was opened before the sanctions were introduced (for example, before 2022) does not exempt a person from the obligation to comply with the sanctions in force. If a credit institution is added to a sanctions list, the individual must immediately cease cooperation with that institution and close the account or terminate the deposit agreement as soon as possible.
Yes, the sanctions framework does not prohibit contacting a credit institution included on the sanctions list in order to terminate the client-bank relationship. The procedure for closing the account depends on the agreement with the respective credit institution.
Yes, it is possible to withdraw funds from such an account, but it must
be taken into account that when a credit institution is placed on the EU
sanctions list, the sanctions framework sets out the procedure whereby a person
may withdraw funds from such a credit institution upon obtaining authorisation
from the competent authority (in Latvia – the FIU).
Currently, the FIU may authorise a one-off transfer of funds to the EU from a
sanctioned credit institution, provided that the conditions set out in Article
6b(5i) of Regulation No. 269/2014 are fulfilled (for example, neither the
sender nor the recipient is a sanctioned person). The FIU explains that each
case is assessed individually. Further information on submitting an application
for authorisation is available here.
In general, making payments to Russia or Belarus is not prohibited, provided that the payment recipient or the recipient’s credit institution is not a sanctioned entity and that the payment is not restricted by sectoral sanctions.
It should be noted that even if the transaction is not restricted by sanctions, credit institutions may refuse to execute the transaction if it does not comply with the institution’s risk policy (for example, if the credit institution does not process incoming or outgoing payments to Russia or Belarus).
Yes. In certain cases, it is permissible to receive payment from a business partner in Russia or Belarus for goods exported at a time when the relevant supply was permitted, including during the transitional period. The purpose of the export prohibition is to prevent Russia and Belarus from obtaining access to certain goods, whereas payment is an obligation of the purchaser, the performance of which may be beyond the control of the EU operator.
Receipt of such payment may be permissible, provided that no new prohibited supply is made, the business partner is not subject to sanctions, and the receipt of the payment does not result in a breach of any other restrictions laid down in the sanctions framework.
Where an invoice includes different categories of goods, it is important to ensure that the payment is allocated only to those supplies that were lawful at the time they were carried out, thereby distinguishing goods subject to sanctions from other goods.
Where an exemption permits the conclusion of a new contract, the EU operator should ensure that payment for the goods is made before the expiry of the period specified in the exemption. Receipt of payment after the expiry of that period is not permitted.
No. The purpose of the import prohibition is to deny Russia and Belarus access to certain sources of revenue, whereas making payment is an obligation of the EU operator and is within its direct control. The EU operator is required to ensure that the entire transaction, including the payment, is completed within the transitional period specified in the exemption.¹
¹ Question 10 of Section A, point 3, of the European Commission’s “Consolidated FAQs on the implementation of Council Regulation (EU) No 833/2014 and Council Regulation (EU) No 269/2014.”
Yes. In such a case, the continuation of an already initiated deposit service is permitted. At the same time, the credit institution must ensure that the amount of the deposit is not increased – including by refraining from crediting interest to the client’s account.
The credit institution and the client must agree on the procedure and place for the payment of deposit interest if the total balance of the client’s accounts held with the same credit institution exceeds the threshold set out in Article 5b of Regulation No 833/2014.¹
¹ Question 26 of Section C, point 5 of the European Commission’s “Consolidated FAQs on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014.”
Yes. It is permissible to provide a new deposit service to a client who is subject to the prohibition on accepting deposits laid down in Article 5b of Regulation No 833/2014, provided that the total balance of deposits held by that client with the same credit institution does not exceed EUR 100,000.¹
¹ Question 14 of Section C, point 5 of the European Commission’s “Consolidated FAQs on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014.”
Yes. Opening a new deposit for a client whose total deposit balance with the same credit institution exceeds EUR 100,000 is prohibited and may be regarded as a sanctions violation.¹ Since the provision of a new deposit service results in the accumulation of additional funds for the client, such action is incompatible with the objective of Article 5b of Regulation No 833/2014, which is to restrict the ability of certain persons to place deposits with credit institutions established in the European Union.
¹ Question 14 of Section C, point 5 of the European Commission’s “Consolidated FAQs on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014.”
No. In general, payment cards, as smart cards, fall under CN code 8523, which is listed in Annex XXIII to Regulation No 833/2014 and in Annex XXIII to Regulation No 765/2006. Accordingly, Article 3k(1) of Regulation No 833/2014 and Article 1bb(1) of Regulation No 765/2006 prohibit the sending of payment cards to Russia and Belarus.
A credit institution must assess the risks in each individual case and obtain sufficient information to ensure compliance with the sanctions regulatory framework.
For example, a citizen of Russia is prohibited, while being physically present within the territory of the European Union, from providing the services listed in Article 5n(1) of Regulation No 833/2014 (business and management consulting services) to legal persons established in Russia. Therefore, the credit institution must ensure that the services for which the client receives salary payments in Latvia have not been provided within the territory of the European Union.
Yes, in such a case, a credit institution may credit funds to the account of a sanctioned person, and a separate authorisation from the FIU is not required. Pursuant to Article 7(1) of Regulation No. 269/2014 and Article 4(2) of Regulation No. 765/2006, financial institutions or credit institutions are not prohibited from crediting a payment from a sanctioned person if the sanctioned person transfers funds to itself from an account held outside the European Union to its account in Latvia, provided that such funds are immediately frozen. The financial institution or credit institution must immediately inform the relevant competent authority of each such transaction.
Accepting funds from a sanctioned person’s account outside the European Union and freezing them in the sanctioned person’s account in Latvia, thereby increasing the amount of frozen funds, is consistent with the objectives of the restrictive measures. Any further actions with the frozen funds may only be carried out in accordance with authorisations issued by the competent authority (FIU).
The Combined Nomenclature (CN) is a classification system for goods used in the European Union for the uniform recording of all imported and exported goods. The list is based on the internationally recognized Harmonized System (HS), which is widely used worldwide.
The HS is an international catalogue of goods codes in which each product is assigned a six-digit code. This system is used by more than 200 countries; therefore, the first six digits of a goods code are identical in almost all countries applying the HS.
On the basis of the HS, the European Union has developed the CN, in which the classification of goods is further detailed to eight digits.
To identify whether a specific good is subject to any prohibitions laid down in the sanctions regulatory framework, it is recommended first to consult the current consolidated version of the relevant regulation and then also use the Integrated Tariff Management System of the State Revenue Service or the EU TARIC database. Where a CN code is indicated in a regulation at the four- or six-digit level, it also covers all corresponding, more detailed eight-digit CN codes falling within that classification heading, unless the wording of the regulation provides for a narrower scope. Therefore, both the goods code and the specific wording of the regulation, including the relevant annex, must always be assessed.
Additional information on CN codes is available on the website of the State Revenue Service (available in Latvian language). Product CN codes and related regulatory requirements can also be found in the State Revenue Service’s Integrated Tariff Management System.
The items and their CN codes are included in specific annexes to Regulation No 833/2014 and Regulation No 765/2006. In order to identify whether a particular item is subject to one of the prohibitions (sanctions) included in these Regulations, we recommend that you open the website of the relevant Regulation in your browser and use the search function to search the website for the CN code of the item, or for a specific Article of the Regulation, or its annex.
If the CN code of an item is included, for example, in Annex X to Regulation No 833/2014, the item will be subject to the prohibition specified in Article 3b of Regulation No 833/2014 on the sale, supply, transfer or export to Russia or for use in Russia of the items and technology listed in Annex X.
Where a CN code is indicated in a regulation at the four- or six-digit level, it also covers all corresponding, more detailed eight-digit CN codes falling within that classification heading, unless the wording of the regulation provides for a narrower scope (both the goods code and the specific wording of the regulation, including the relevant annex, must be assessed).
In addition, the following sources can be used to check whether a particular CN code is subject to a prohibition:
or
It should also be noted that Annex VII to Regulation No. 833/2014 and Annex Va to Regulation No. 765/2006 include goods that are not identified by a specific CN code but are described by their characteristics. Accordingly, it is necessary to verify whether the exported goods correspond to any of the descriptions listed in Annex VII to Regulation No. 833/2014 or Annex Va to Regulation No. 765/2006.
If there is any doubt as to whether specific goods are considered to be included in Annex VII to Regulation No. 833/2014 or Annex Va to Regulation No. 765/2006, it is possible to consult the Strategic Goods Export Control Division of the Ministry of Foreign Affairs.
If a product’s CN code is listed in multiple annexes of Regulation No 833/2014 or Regulation No 765/2006, each applicable Article must be complied with separately. This means that activities involving such a product may only be carried out if all sanctions provisions applicable to that product are fully observed.
If the product is included in several annexes—for example, in two annexes of Regulation No 833/2014 to which different Articles with different prohibitions apply—an exemption is available only if both Articles provide for an exemption and if the authorisation has been obtained from the respective competent authority or authorities. If one of the Articles does not provide for an exemption, no authorisation will be issued.
For instance, if a product is included in two annexes, and one of them concerns items of strategic significance, both an authorisation from the FIU with regard to the applicable exemption under Regulation No 833/2014 and an authorisation from the Ministry of Foreign Affairs’ Strategic Goods Export Division for the export of strategic goods would be required.
It should be noted that products listed in multiple annexes of the Regulations are often preceded by the designation “ex” before the CN code, which means that the prohibition applies only to the product that meets both the CN code and the specific product description set out in the annex.
Yes. Where goods subject to sanctions are transported from a third country to Russia or Belarus and transit the territory of the European Union, the prohibition laid down in Regulation No 833/2014 and Regulation No 765/2006 on directly or indirectly selling, supplying, transferring or exporting such goods to Russia or Belarus applies.¹
The prohibitions laid down in Regulation No 833/2014 and Regulation No 765/2006 on selling, supplying, transferring or exporting goods are interpreted broadly in order to ensure the effective implementation of sanctions and to prevent their circumvention.
Accordingly, where goods are subject to an export prohibition and are destined for Russia or Belarus, the restrictions also apply where such goods are transported in transit through the territory of the European Union, irrespective of the applicable customs procedure.
¹ Question 24 of Chapter 1 of Section D of the European Commission’s “Consolidated FAQs on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014.”
Regulation No 833/2014 and Regulation No 765/2006provide for a number of restrictions concerning the transit of specific goods through the territory of Russia or Belarus.¹
To determine whether the transit of specific goods is permitted, it is first necessary to identify the goods and their Combined Nomenclature (CN) code, and then to verify the relevant provision and annex of the applicable regulation.
For example, if the CN code of the goods is included in Annex XXXVII to Regulation No 833/2014, the prohibition on their transit through the territory of Russia laid down in Article 3k(1a) of that Regulation will apply.
Regulation No 833/2014 also explicitly prohibits the transit through Russia of certain other categories of goods, including dual-use goods, certain military-sensitive goods, firearms, as well as certain goods in the aviation and space sectors.
With regard to goods listed in the sanctions regulatory framework, transit through Russia or Belarus to a third country may be permitted, provided that it is not otherwise prohibited. In such cases, the exporter must be able to demonstrate that the goods are genuinely intended for delivery to a third country and are not made available for use in Russia or Belarus. Where, upon assessment of the applicable regulation, it is established that a transit prohibition applies to the specific goods, such transit is not permitted, except in cases where the relevant provision of the regulation provides for an exemption or a derogation.
Where the regulation provides for an exemption, the activity in question may be permitted provided that all the conditions of the exemption are fully met.
Where the regulation provides for a derogation, the person may submit an application to the FIU to obtain an authorisation for carrying out the transit. Further information on submitting an application to the FIU for authorisation is available here.
¹ For example, Article 2(1)(a), Article 2a(1)(a), Article 2aa(1)(a), Article 3c(1)(a), and Article 3k(1)(a) of Regulation No 833/2014lay down a prohibition on the transit of the goods listed therein through Russia of the goods specified therein. In relation to Belarus, the relevant provisions and annexes of Regulation No 765/2006 applicable to the specific category of goods must be assessed.
The dispatch of such goods from Russia to third countries (including in transit through Latvia) is prohibited. At the same time, it should be noted that, although Clause 12 of the Preamble of Regulation No 2022/1269 provides that restrictive measures are not aimed at trade in the specified products between third countries and Russia¹ in order to preventively avert the occurrence of food insecurity conditions in third countries, the European Commission has indicated that this does not limit Member States from taking the necessary measures to protect their national security interests.²
Taking into account that Russia continues its war of aggression against Ukraine and that any trade with Russia increases its budget revenues and its ability to continue the war, Latvia is entitled to restrict trade between Russia and third countries in cases where goods are transported in transit through Latvia to third countries. Accordingly, in the context of national security, any trade that generates income for the aggressor state is to be regarded as a threat to national security and also contributes to the continuation of Russia’s war of aggression against Ukraine.
¹ Council Regulation (EU) 2022/1269 of 21 July 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, Clause 12 of the Preamble.
² European Commission Guidelines “Consolidated FAQs on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014”, Part D, Chapter 5, Question 2.
No, generally, such re-importation is not considered an import within the meaning of the sanctions regulatory framework. If the EU regulations provide for a prohibition on importing certain goods, but those goods are returned to the consignor in Latvia in full and in the same quantity and condition as when they were exported, this action is not regarded as a new transaction but rather as a restoration of the situation prior to export.
The decision as to whether a particular re-importation meets these conditions and which customs procedure should be applied is taken by the State Revenue Service’s Customs Board as the competent authority in the field of customs. The Customs Board assesses each case individually, taking into account the factual circumstances, including whether the goods are returned in full and in the same condition as when they were sent to Russia or Belarus.
The Financial Intelligence Unit (FIU) additionally notes that the Customs Board has the right to refuse the re-importation of goods if there are reasonable grounds to suspect a potential sanctions violation.
In general, the competent authorities of a Member State may authorise the
importation of goods if both of the following conditions are met:
Given that this derogation allows the importation of goods only when they are intended for the personal use of natural persons travelling to the European Union or their immediate family members (i.e., the goods are brought in together with the arriving person), this derogation does not apply in cases where the person has already entered the European Union (Latvia) and the goods are imported at a later time.
It should additionally be noted that goods may be imported only if it can be established that they are intended for the personal use of the arriving persons. The arriving person may be required to present certain documents to the State Revenue Service Customs Board and, where necessary, to provide explanations regarding the goods being imported from Russia or Belarus.
1 Article 3i(3)(aa) of Regulation No 833/2014 and Article 1ra(4) of Regulation No 765/2006.
Steps:
For example, if the CN code of the item is included in Annex XVIII to Regulation No. 833/2014 (luxury goods with a value exceeding EUR 300), the prohibitions laid down in Article 3h of Regulation No. 833/2014 apply. Conversely, if the CN code of the item is included in Annex XXV to Regulation No. 765/2006 (luxury goods with a value exceeding EUR 300), the prohibitions laid down in Article 1ga of Regulation No. 765/2006 apply.
2. If the export of the item is not subject to the prohibitions of Regulation No. 833/2014 or Regulation No. 765/2006, or if an exemption from the implementation of sanctions applies, the person may export the goods to Russia or Belarus without a separate FIU authorisation.
3. If a derogation applies under the relevant regulation, the person has the right to apply to the FIU for authorisation to perform the export of the specific item.
For example, Article 3h of Regulation No. 833/2014 and Article 1ga of Regulation No. 765/2006 do not provide derogations regarding the transfer of personal belongings to Russia or Belarus.
The FIU explains that a person must verify whether the Combined Nomenclature (CN) code of the item is not included in the annexes to Regulation No. 833/2014 or Regulation No. 765/2006 prohibiting the export of goods to Russia or Belarus.¹
For example, hats are classified under CN codes 6501 – 6507, and generally, under EU sanctions, sending them to a friend in Russia or Belarus is not prohibited. However, if the hat is a designer model or made of luxury materials and its price exceeds EUR 300, sending such an item to a friend is prohibited.
The FIU further notes that it is also necessary to ensure that the person to whom the good is intended to be sent is not subject to EU sanctions (a sanctioned person).
On its official website, the FIU maintains a section “Search on sanctions lists”, which provides information on sanctioned person – natural or legal persons, or other identifiable entities subject to UN, EU, or national sanctions of Latvia.
¹ Provided that the item is also not considered a dual-use good within the meaning of Regulation (EU) 2021/821 of the European Parliament and of the Council of 20 May 2021 establishing the Union regime for the control of exports, brokering, technical assistance, transit, and transfer of dual-use items.
No, the temporary import to or export from the European Union for the purpose of moving items does not constitute an export/import of the item, unless the items are used for the transport and temporary storage of other items from Russia or Belarus to the European Union or vice versa and the purpose of the import/export thereof is the sale and release for free circulation. Such items are, for example, containers falling within Combined Nomenclature (CN) code 8609.
The FIU explains that Latvia’s cooperation with Russia and Belarus in the fields of justice, judicial cooperation, internal affairs, environmental protection, nuclear safety, customs, tax administration, healthcare, state border protection, transport, culture education, cross-border cooperation and other areas has been suspended or reduced to the minimum necessary to ensure the day-to-day functioning and performance of the functions of Latvian state and municipal authorities.
The relevant regulations provide for derogations permitting the export of certain goods to Russia or Belarus where those goods are intended for medical or pharmaceutical purposes.¹ At the same time, the FIU notes that the application of such derogations should be applied to the export of medical goods only in exceptional and specific circumstances – for a one-off transaction rather than to facilitate ongoing commercial activities. Each case is assessed individually, taking into account all the relevant factual and legal circumstances.
The derogations provided for in the relevant regulations are not intended to serve as a legal basis for the regular or repeated export of prohibited goods to Russia or Belarus for commercial purposes. In this context, trade that generates income for the aggressor state may pose a threat to Latvia’s national security and indirectly strengthen the capacity of Russia’s capacity to continue its war of aggression against Ukraine.
¹ Article 3k(5)(a) of Regulation No 833/2014 and Article 1bb(8)(a) of Regulation No 765/2006.
If there is a composite, finished product that is classified under a single Combined Nomenclature (CN) code and no prohibitions laid down in the sanctions regulatory framework are applicable to that product, the said product is permitted to be exported from the European Union, including in cases where restrictions laid down in the sanctions regulatory framework are applicable to individual components or parts forming part of the product.
In order to determine the appropriate CN code for a finished, composite product, technical information on the product may be required.
At the same time, it must be assessed whether the export of such a product is not intended to circumvent the export restrictions on goods laid down in the sanctions regulatory framework.
All goods intended to be exported from the customs territory of the European Union must be presented to the customs authority, and an appropriate customs procedure or re-export must be applied to them. For the application of a customs procedure or re-export, a customs declaration (export or transit declaration) or a re-export declaration must be submitted (in certain cases – an exit summary declaration or a re-export notification).
For the export of European Union goods, the customs procedure of export is applied. The export declaration must indicate the goods prepared for export (loaded onto the means of transport).
Answer to the question has been prepared in cooperation with the National Customs Board of the State Revenue Service.
If, within a single consignment, all parts necessary for the assembly of a specific product are present, they shall be classified under one Combined Nomenclature (CN) code, namely the code applicable to the assembled product. The complexity of the method of assembly does not affect the classification. However, such parts must not undergo any further processing in order to manufacture a finished product.
Accordingly, the export conditions for unassembled goods that are classified as assembled goods under one CN code are identical to the export conditions for assembled, finished goods or goods exported as a single unit (see the answer to the previous question).
Where not all parts necessary for the assembly of a specific product are contained in a single consignment, each case must be assessed individually in order to determine whether each part is to be classified separately under its corresponding Combined Nomenclature (CN) code (for example, electric motors under CN heading 8501, diodes and transistors under CN heading 8541, cables under CN heading 8544), or whether they are to be classified under the CN code applicable to the assembled product as unassembled or disassembled goods that possess the essential characteristics of the finished, assembled product.
Taking into account that the assessment of such cases may be complex, in cases of uncertainty it is possible to consult the National Customs Board of the State Revenue Service.
Answer to the question has been prepared in cooperation with the National Customs Board of the State Revenue Service.
Yes. In cases where goods are transported from a third country to Russia or Belarus and pass through the territory of the European Union, the prohibition laid down in Council Regulation No 833/2014 and Council Regulation No 765/2006 on directly or indirectly selling, supplying, transferring or exporting goods to Russia or Belarus applies.¹ Likewise, the prohibition under Council Regulation No 833/2014 and Council Regulation No 765/2006 on purchasing, importing or transferring goods may also apply to transactions in which goods from Russia or Belarus are transported to a third country via the territory of the European Union.
The terms “export” and “import” as used in Council Regulation No 833/2014 and Council Regulation No 765/2006 are interpreted broadly to ensure the effective application of sanctions and to prevent their circumvention. Therefore, the restrictions generally also apply to transactions involving the transit of goods through the territory of the European Union.
________________________________________
¹ Question 24 of Section D, Chapter 1, Questions 2 and 6 of Chapter 5, and Questions 1 and 2 of Chapter 6 of the European Commission’s “Consolidated FAQs on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014.
Yes, generally, such goods may be sold, provided that they were lawfully imported into the territory of the European Union prior to the entry into force of the restrictions laid down in Council Regulation No 833/2014 or Council RegulationNo 765/2006.¹
At the same time, it should be noted that each case must be assessed individually, and the person is obliged to ensure that no other applicable sanctions restrictions or legal provisions are infringed in the course of the specific activity.
¹ Article 12e of Council Regulation No 833/2014 and Article 8f of Council Regulation No 765/2006.
No, a framework agreement (master agreement) is not, in itself, necessarily considered a prior contract within the meaning of sectoral sanctions.¹ This depends on the specific provision of the sanctions regulation and on the content of the framework agreement.
In order for a contract to be regarded as one that gives rise to the right to rely on exemptions provided for in the sanctions framework in respect of the performance of prior contracts, it must include the essential elements of the transaction and provide for a binding obligation on the parties to carry out a specific transaction (for example, with regard to the quantity of goods, price, etc.).
If a framework agreement merely sets out general principles of cooperation but does not provide for specific obligations to carry out a defined transaction, it is not considered a prior contract within the meaning of sectoral sanctions and cannot serve as a basis for applying an exemption from sanctions.
¹ Question 2 of Section A, Chapter 3 of the European Commission’s “Consolidated FAQs on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014.”
For the purposes of the international sanctions framework, the provision of rental, lease, legal or any other type of services is considered to constitute the making available of economic resources to a person included on the sanctions list and a person subject to sanctions (owned or controlled by a person included on the sanctions list). Given that the sanctions regulations prohibit the direct or indirect making available of economic resources, the provision of any services to persons subject to targeted financial sanctions is prohibited.
It must be emphasised that the sanctions framework introduced against Russia and Belarus (see Regulation No 833/2014 or Regulation No 765/2006) provides for general prohibitions on the provision of various services to a certain range of persons, such as legal entities established in Russia, the Government of Russia, etc. Examples of such prohibited services are: public relations; advertising; accounting; construction; architectural; engineering; IT; legal advisory services; and also tax consulting services.
At the same time, the sanctions framework provides for the application of exemptions and derogations in the implementation of sanctions—where, respectively, a specific action is not considered a breach of sanctions because it strictly complies with the conditions defined in the regulation, or where, in cases defined as derogations under the sanctions regulations, the competent authority of a European Union Member State (in Latvia – the FIU) may authorise the performance of otherwise prohibited activities. Further information on submission of the application for authorisation is available here. For example, the FIU may allow the rental of an apartment to a sanctioned person or allow the provision of legal services if deemed necessary to meet the basic needs of the person. The FIU closely monitors the provision of and payment for such services carried out in accordance with the authorisations issued.
If it is intended to provide services prohibited according to Regulation No 833/2014 to a person subject to the restrictions laid down in Regulation No 269/2014, authorisation from the competent authority must be obtained based on the exemptions specified in both regulations.
Every person has the obligation to comply with and implement the sanctions binding to Latvia. Therefore, before concluding a transaction, it is necessary to make sure that the specific person (counterparty) does not classify as a person directly subject to targeted financial sanctions or as a person indirectly subject to sanctions. As part of the counterparty verification, it is necessary to ascertain that:
In addition, it must be verified whether the sectoral sanctions framework (for instance, Regulation No 833/2014 and Regulation No 765/2006) imposes a prohibition on providing the specific service (for instance, the prohibition to provide IT consultancy services to a company established in Russia). It should be noted that sanctions should be interpreted broadly to ensure the effectiveness of restrictive measures and to prevent their violation. For instance, providing services to a subsidiary could result in those services being directly or indirectly accessible to its parent company based in Russia or Belarus, which may ultimately benefit from them. Such actions, if prohibited by sanctions, may be considered a violation of international and national sanctions, for which Section 84 of the Criminal Law provides criminal liability.
Pursuant to Article 5n(1) of Regulation No 833/2014, the provision of certain services¹ to the Government of Russia, as well as to any legal person, entity or body registered in Russia, is prohibited.
In turn, pursuant to Article 1jc(1), (2), (3) or (4a) of Regulation No 765/2006, the provision of such services to Belarus, its government, its state authorities, enterprises or agencies, as well as to persons acting on behalf of or at the direction of those entities, is prohibited.
As of 24 October 2025², the direct or indirect provision of any other services not listed in the above-mentioned regulatory framework to the Government of Russia or to Belarus, its government, state authorities, enterprises or agencies, is prohibited and is permissible only with the prior authorisation of the competent authority.³
More detailed information on the submission of an application for obtaining an authorisation is available here.
At the same time, the sanctions regulatory framework also provides for other prohibitions relating to the provision of certain services, which must be assessed by each person on an individual basis.
It should be taken into account that actions prohibited under the sanctions regulatory framework may be recognised as a breach of international and national sanctions, for which criminal liability is provided for under Section 84 of the Criminal Law.
¹ For example, accounting, auditing and tax consulting services, business and management consulting services, legal, IT, architectural and engineering services, public relations, advertising, market research, technical testing services, and services related to business management or industrial design software.
² Article 5n(8c) of Regulation No 833/2014 and Article 1jc(10b) of Regulation No 765/2006 provide for a transitional period until 1 January 2026, namely that the provision of services during this period without an authorisation from the competent authority is possible where the service is provided on the basis of a contract concluded by 23 October 2025.
³ Article 5n(4) of Regulation No 833/2014 and Article 1jc(5a) of Regulation No 765/2006.
For the purposes of the sanctions framework, the diplomatic missions and consular posts of Russia and Belarus are regarded as forming part of the governments of those States. Accordingly, the above-mentioned restrictions on the provision of services generally also apply to them.
From 24 April 2026,¹ services that are strictly necessary for the functioning of the diplomatic missions and consular posts of Russia and Belarus in Latvia may be provided without obtaining a separate authorisation from the FIU.² At the same time, Regulation No 833/2014 and Regulation No 765/2006 continue to provide for certain services that may be supplied only in specific, narrowly defined circumstances in accordance with the sanctions framework and may require prior authorisation from the FIU.
It should also be noted that the exemption introduced on 24 April 2026 by Regulation No 833/2014 and Regulation No 765/2006 applies solely to the restrictions on the provision of services. It does not, in itself, remove any other restrictions laid down in Regulation No 833/2014, Regulation No 765/2006 or other sanctions legislation, such as restrictions on the acceptance of deposits, the issuance of payment cards, the provision of funds or financial assistance, or other activities. In such cases, the relevant restriction must be assessed separately, and an individual authorisation from the FIU may be required.
Until 24 April 2026, the provision of certain services (such as utility services, electronic communications services, financial services and other services) to the diplomatic missions and consular posts of Russia and Belarus was permitted pursuant to the FIU's Decision No 13-1/301 of 30 December 2025, a general administrative act.³
Further information on the above-mentioned FIU Decision is available here, under the section “General Authorisation for the Functioning of the Diplomatic Missions and Consular Posts of Russia and Belarus”.
It should also be noted that Regulation No 833/2014 and Regulation No 765/2006 do not impose a general prohibition on providing services to diplomats or to members of the staff of embassies and consular posts acting in their personal capacity.
Before providing any services, the service provider should ensure that the provision of those services does not violate the sanctions framework, including by assessing whether the invoice for the services will be paid by the diplomatic mission or consular post, or by the individual concerned.
¹ Council Regulation (EU) 2026/513 of 23 April 2026 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in Russian aggression against Ukraine; and Council Regulation (EU) 2026/506 of 23 April 2026 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine.
² Article 5n(4a) of Regulation No 833/2014 and Article 1jc(5b) of Regulation No 765/2006.
No. As of 24 October 2025, the provision of such services is prohibited.¹ The prohibition applies, for example, to services provided by travel agencies and tour operators, tourist guide services, as well as related advertising and other services² that are provided within the territory of Russia, namely excursions taking place within Russia proper or in its exclave (for example, the Kaliningrad Region).
The restriction on the provision of tourism services shall not be regarded as a comprehensive prohibition on travel to Russia for private purposes or otherwise. Accordingly, certain services, such as the sale of transport tickets or ticket sales provided as an intermediary service, are not prohibited, provided that such services do not infringe the advertising prohibition laid down in Article 1(zj) of Regulation No 833/2014.
Each service provider has an obligation to assess on a case-by-case basis whether a specific service, within the meaning of Regulation No 833/2014, is to be regarded as a service that is directly related to tourism activities in Russia.
The objective of the prohibition is to reduce the revenues of Russia and to protect European Union citizens, taking into account the heightened security risks and the limited availability of consular protection in Russia.
¹ Article 5n(2) of Regulation No 833/2014.
² Article 1(zj) of Regulation No 833/2014 defines which services are
considered to be directly related to tourism activities.
No person may, either directly or indirectly, provide funds or economic resources to a sanctioned person, including through fund transfers, cash provision, or the supply of any other services. Similarly, a sanctioned person may not transfer funds or cash to another person. If a counterparty is a sanctioned person, any person must, to the extent possible, freeze all funds and economic resources belonging to that party and notify the FIU immediately. Explanations regarding the obligation to report information to the FIU are available here.
In certain circumstances, such as when funds or economic resources are required to cover basic needs (including food, medical care, utilities, etc.), payments may be made or services provided, if the conditions set out in the FIU General Licence are complied with or a separate FIU authorisation is obtained.1
Although Section 13.1 of the Law on International Sanctions and National Sanctions of the Republic of Latvia requires credit institutions to establish an internal control system for sanctions, everyone is required to comply with sanctions and carefully verify the recipients of transferred funds.
1 More information on obtaining authorisation from the FIU and key considerations when applying for such authorisation can be found here.
The term “consulting in the field of business and management” refers to consulting, advisory, and operational assistance services provided to companies regarding their business policies and strategies, general planning of the organisation, its structure, and control. This category includes management fees, management audits, market, human resources, production, and project management consulting, as well as advisory and operational assistance services related to improving the client’s image and its relations with the public and other organisations.¹
According to Article 5n of Regulation No. 833/2014, the provision of such services is prohibited both to the Government of Russia and to any legal person registered in Russia. Meanwhile, according to Article 1jc of Regulation No. 765/2006, the provision of such services is prohibited only to Belarus, its government, state institutions, companies, or agencies.
For example, if a manager participates in the preparation of a proposal concerning the policy, strategy, business planning, or organisational structure of their represented company, such conduct may be considered a violation of sanctions.
The FIU emphasises that what is prohibited is the provision of services, not the holding of specific positions.
However, even in cases where a person holds, for instance, the position of:
— there remains a high risk that the actual activity will go beyond purely technical functions and will involve prohibited elements of consulting.
Yes. In accordance with Regulation No 833/2014 and Regulation No 765/2006, a natural or legal person of Latvia is, in general, not prohibited from being the owner of shares in a legal person registered in Russia or Belarus.
At the same time, it must be taken into account that the said Regulations lay down extensive sectoral sanctions restrictions. For example, the provision of certain services, including legal services, IT consultancy services, management services and other services, to the Government of Russia or to legal persons, entities or bodies established in Russia, as well as to Belarus, its government, public bodies, enterprises or agencies, including persons acting on their behalf or under their instructions, is prohibited.
Thus, ownership of shares in itself is not prohibited; however, a person must assess on an individual basis whether activities related to the holding of such shares are subject to the restrictions laid down in the sanctions regulatory framework.
Although the European Union sanctions regulatory framework may not be directly applicable in third countries, natural and legal persons of the Member States of the European Union are required to apply best efforts to ensure that any legal person, entity or body owned or controlled by them does not participate in activities that violate sanctions.¹
This means that the person must actively assess the scope of their influence and take proportionate measures, applying best efforts, to prevent the circumvention or violation of sanctions through a legal person owned or controlled by them.
Additional information on this obligation is available in the European Commission guidelines “Consolidated FAQs on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014”, Section A, subsection 4.
¹ Article 8a of Regulation No 833/2014 and Article 8i of Regulation No 765/2006.
Holding such a position in itself does not constitute a breach of sanctions; however, by holding the position of director or general director, there is a high risk that the actual activities performed will include elements of prohibited management consulting services.
It should be noted that the provisions of the sanctions framework are deliberately drafted broadly in order to prevent situations where the rules are complied with only formally, without achieving the objectives of the sanctions. Therefore, any managerial position in a legal person registered in Russia or Belarus may indicate a potential breach of sanctions, and each case must be assessed individually, taking into account the factual circumstances.
The FIU indicates that leaving Latvia for Russia or Belarus with one’s personal vehicle is not prohibited; however, the restrictions laid down in Regulation No. 833/2014 or Regulation No. 765/2006 must be observed.
Such departure is considered an export and must be carried out in accordance with the prohibition on exporting certain types of vehicles to Russia or Belarus, as specified in Article 3k of Regulation No. 833/2014 or Article 1bb of Regulation No. 765/2006.
Therefore, if the Combined Nomenclature (CN) code of the vehicle is, for example, ex 8703 23 (a motor vehicle designed for the transport of fewer than 10 persons with an engine capacity exceeding 1,900 cm³), which is listed in Annex XXIII to Regulation No. 833/2014 or Annex XVIII to Regulation No. 765/2006, the prohibition laid down in Article 3k(1) of Regulation No. 833/2014 or Article 1bb(1) of Regulation No. 765/2006 on exporting the item from the European Union applies.
Yes, in certain cases. Where a vehicle is registered in Latvia, bears Latvian registration plates, is driven under its own power, and is intended to return to the European Union after the journey, such movement will generally not be regarded as the export of the vehicle (as goods) to Russia or Belarus.¹
It should be noted that certain categories of vehicles may not be sold, supplied, transferred, exported or otherwise taken out for use in Russia or Belarus. Customs officials at the border crossing point may assess potential sanctions circumvention or violation risks. The customs authority may decide whether to permit the vehicle to leave the European Union only after assessing the specific circumstances at the border crossing point.
¹ Article 1bb(1) of Regulation No 765/2006 and Article 3k(1) of Regulation No 833/2014 prohibit the direct or indirect sale, supply, transfer or export of certain vehicles to any natural or legal person, entity or body in Russia or Belarus, or for use in Russia or Belarus.
Generally, the import of vehicles (including bringing in or entering with a vehicle) into the European Union from Russia or Belarus is prohibited if the vehicle is listed in Annex XXI to Regulation No 833/2014 or Annex XXVII to Regulation No 765/2006 (for instance, the vehicle corresponds to Combined Nomenclature (CN) code 8703 – Motor cars and other motor vehicles principally designed for the transport of < 10 persons, including station wagons and racing cars).
Furthermore, in accordance with Section 10(16) of the Road Traffic Law, it is prohibited to participate in road traffic in Latvia with vehicles registered in Russia or Belarus, unless otherwise provided by law.
The Road Traffic Law provides for only two exceptions under which the FIU may issue an authorisation for entry into the European Union through the Latvian border with a vehicle registered in Belarus:
1 Relatives in the direct line: parents, grandparents, etc. (ascendants) and children, grandchildren, etc. (descendants).
In general, according to Section 10, Article 1.6 of the Road Traffic Law, vehicles registered in Russia and Belarus are prohibited from participating in road traffic in Latvia.
However, transitional provision Article 69 of the Road Traffic Law allows limited use of such vehicles under the following conditions:
As explained in the Road Traffic Law annotation, this provision is intended solely for the return of the vehicle to its country of registration.
The General Licence is a decision issued by the Financial Intelligence Unit (FIU) on 20 February 2026 — a general administrative act that has been in force since 20 February 2026.
This regulation specifies the categories of payments that sanctioned persons (subject to the freezing of funds and economic resources and the prohibition on making funds or economic resources available to them) may make without requiring separate authorisation from the Financial Intelligence Unit (FIU).
Further information on the General Licence is available here.
Yes, payments, the execution of which was initiated by 20 February 2026 in accordance with decision No. 13-1/147 of 27 December 2024 “Regarding Determination of Authorised Payments”, may also be completed after the entry into force of the new General Licence.
At the same time, it must be taken into account that after 20 February 2026 the execution of such payments takes place in accordance with the provisions and conditions of the new General Licence.
No, a payment may not be made on behalf of a sanctioned person. Clause 8 of the General Licence stipulates that it does not confer any right to make or receive payments where such payments are made by third parties for the benefit of sanctioned persons, thereby directly or indirectly making funds and economic resources available to such persons.
For example, under the General Licence, a sanctioned person is permitted to settle an invoice for electricity received. However, taking into account Clause 8 of the General Licence, no other person is permitted to pay this invoice on behalf of the sanctioned person.
The sale of goods and the provision of services to a sanctioned person are generally prohibited. However, Clause 3 of the General Licence stipulates that natural and legal persons in the territory of Latvia are permitted, in accordance with the payment categories specified in Annex 1 of the General Licence and subject to the time limits and payment amount restrictions set forth therein, to sell goods, provide services, and receive payments from sanctioned persons in credit institutions registered in the European Union, financial institutions registered in the European Union, and the State Treasury.
For example, Clause 1 of Annex 1 of the General Licence lists payments related to the basic needs, daily living, and health maintenance of natural persons and their dependent family members, including food, hygiene products, and medicines. The sale of such goods to a sanctioned person and the receipt of payment therefor are permitted under the General Licence without requiring a separate authorisation from the Financial Intelligence Unit (FIU).
Similarly, the General licence allows a sanctioned person to make payments for natural gas, its distribution, transmission, and subscription services. The provision of such services to a sanctioned person is permitted under the General Licence without requiring a separate FIU authorisation.
If a natural or legal person wishes to sell goods or provide services to a sanctioned person that do not fall within the payment categories specified in Annex No. 1 of the General Licence or that exceed the time limits or payment amount restrictions set forth therein, they must obtain prior authorisation from the FIU before selling the goods or providing the services.
Yes, a sanctioned person may conclude a contract for the receipt of electricity under the General Licence. In accordance with subclause 3.4 of Annex 1 to the General Licence, legal persons are permitted, without a separate FIU authorisation, to make utility payments, including payments for electricity, natural gas, as well as distribution, transmission and subscription services, provided that the immovable property is registered in the Land Register in the name of the legal person.
The General Licence also permits the conclusion of contracts with persons subject to sanctions restrictions where such contracts are aimed at carrying out authorised activities. Accordingly, the conclusion of an electricity supply contract complies with Clauses 2 and 3 of the General Licence, as well as subclause 3.4 of its Annex 1.
Yes. Advance payments are permitted on the basis of the General Licence, provided that they comply with its conditions, including those relating to the payment amount, the payee, and the proportionality of the payment to the person's basic needs.
No specific restrictions or conditions apply to advance payments that differ from those applicable to other types of payments, such as payments made after the service has been provided.
No, unless this is expressly provided for the relevant payment category in the General Licence. The monthly limits set out in the General Licence apply separately to each calendar month and may not be aggregated over multiple months. Any unused portion of a monthly limit is not carried forward to the following month and does not increase the limit applicable to that month.
