Information to be submitted to the FIU

Any person in Latvia has an obligation to immediately inform the FIU of freezing of funds or economic resources (assets) in the European Union or their release from freezing. The person must provide detailed information on the frozen assets, their amount and location, justification for freezing, as well as documents that demonstrate that the asset freezing was performed in compliance with the laws and regulations governing sanctions. Persons have an obligation to cooperate with the FIU in verification of such information.

This obligation is set out in Section 12, Paragraph five of the Law on International Sanctions and National Sanctions of the Republic of Latvia. Documents demonstrating that the freezing of assets was performed in compliance with the requirements of sanctions legislation must be submitted in accordance with Paragraph 21 of the Regulation of the Cabinet of Ministers No 184 “Procedures for the Proposition and Enforcement of International and National Sanctions.

Please use the template available here to provide information on frozen funds.

Please use the template available here to provide information on frozen economic resources.

Any person in Latvia has an obligation to inform the FIU immediately of the implementation of sanctions. Implementation of targeted financial sanctions shall include the freezing of funds or economic resources and release from freezing. Implementation of sectoral sanctions can cover a variety of actions performed to implement sanctions, including but not limited to:

• the termination of a procurement contract concluded with a legal person registered in Russia prior to the imposition of sanctions, with respect to Article 5k of Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine (Regulation No 833/2014);
• resignation of a person from a legal person established in Russia which is under public control, with respect to Article 5aa, subparagraph 1b of Regulation No 833/2014;
• the execution of an activity generally prohibited by sanctions on the basis of an authorisation issued by the competent authority of another European Union Member State.

Any person in Latvia has an obligation to inform the FIU immediately, but no later than within 2 weeks from the date of obtaining the information, abot funds and economic resources in the territory of the European Union that are not frozen but that should be frozen because they belong to, are owned, held or controlled by persons subject to sanctions in accordance with Council Regulation (EU) No 269/2014 of 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) or Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures against President Lukashenko and certain officials of Belarus (Regulation No 765/2006).

Persons must provide detailed information on the funds or economic resources and the justification for freezing. Persons have the obligation to cooperate with the FIU in any verification of such information.

This obligation is set out in Article 8(1) of Regulation No 269/2014 and Article 5 of Regulation No 765/2006 and requires persons to immediately provide any information to the competent authority that would facilitate the implementation of the aforementioned Regulations.

Please use the template available here to provide information on funds and economic resources thar should be frozen.

Any person in Latvia has the obligation to inform the FIU immediately, but no later than within 2 weeks from the date of obtaining the information, about funds and economic resources in the European Union belonging to, owned, held or controlled by sanctioned persons and which in the 2 weeks before the sanctions were imposed or became applicable to the sanctioned person in accordance with Regulation No 269/2014 or Regulation No 765/2006 have been subject to any move, transfer, alteration, use of, access to, or freezing.

Persons must provide detailed information on the funds and economic resources with which actions were taken, including the provision of detailed information on the particular actions taken. Persons have an obligation to cooperate with the FIU in any verification of such information.

This obligation is set out in Article 8(1) of Regulation No 269/2014 and Article 5 of Regulation No 765/2006 that require persons to supply immediately any information to the competent authority and requires persons to immediately supply any information to the competent authority that would facilitate the implementation of the aforementioned Regulations.

The persons listed in Annex I to Regulation No 269/2014 have an obligation to inform the FIU immediately, but no later than within 6 weeks from the date of their listing, of the funds or economic resources owned, held or controlled by them and located in Latvia. The aforementioned information must also be provided without delay by persons who are located in Latvia or who are residents of Latvia and who are listed in Annex I to Regulation No 765/2006.

The persons must provide detailed information on the funds and economic resources in Latvia, including on their type, location, owner, holder, value and other necessary information. The persons have the obligation to cooperate with the FIU in any verification of such information.

The aforementioned obligation is set out in Article 9(2) of Regulation No 269/2014 and Article (5) of Regulation No 765/2006.

Legal persons, entities, and bodies registered in Latvia, whose proprietary rights are directly or indirectly owned for more than 40 % by:

1. a legal person, entity, or body established in Russia;
2. a Russian national (including Russian nationals with dual citizenship); or
3. a natural person residing in Russia;

as of 01.05.2024 must inform the FIU within two weeks of the end of each quarter of any transfer of funds exceeding EUR 100 000 to countries outside the European Union that they have made during that quarter directly or indirectly, in one or several operations. The initial information on such transfers of funds covering the first quarter of 2024 (period from 01.01.2024 till 31.03.2024) is due to be submitted by 15.05.2024. For subsequent periods, information shall be provided within 2 weeks of the end of each quarter, i.e. by 15.07.2024 for the second quarter (April-June), by 15.10.2024 for the third quarter (July-September), etc.

According to the explanation of the European Commission, the reporting obligation also applies to legal persons whose 40% ownership threshold is reached by multiple persons (aggregate ownership) who meet the specified criteria. For example, when 20% of the capital shares of a legal person belong to a Russian national and 20% to a natural person residing in Russia.

The aforementioned obligation is set out in Article 5r(1) of Regulation No 833/2014.

The purpose of Article 5r of Regulation No 833/2014 is to provide the competent authorities of a Member State with the necessary information to enable them to identify transactions, entities, and business sectors that indicate a serious risk of sanctions breaches, circumvention, or use of funds for purposes incompatible with the Regulation.

Considering the abovementioned, persons are required to provide detailed information to the FIU that might be necessary to assess such risk, including information on individual payments, the amount of each payment, information on the recipient of the payment, the credit institution of the recipient, the purpose of the payment, information on the transaction for which the payment is made and other related information. The persons must provide information on their ownership structure which confirms that they are persons obligated to provide the information under Article 5r(1) of the Regulation No 833/2014.

Further information on the reporting obligation can be found in the replies prepared by the European Commission to the frequently asked questions here.

A template for submitting the information is available for download here.

The information must be sent to the email address: sankcijas@fid.gov.lv.

Credit institutions and financial institutions registered in Latvia must as of 01.07.2024 provide information to the FIU within two weeks of the end of each semester on all transfers of funds to countries outside the European Union exceeding in total EUR 100 000 during that semester which they have initiated directly or indirectly for legal persons, entities, and bodies registered in the European Union whose proprietary rights are directly or indirectly owned for more than 40% by:

1. a legal person, entity, or body established in Russia;
2. a Russian national (including Russian nationals with dual citizenship); or
3. a natural person residing in Russia,

According to the explanation of the European Commission, the reporting obligation also applies to legal persons whose 40% ownership threshold is reached by multiple persons (aggregate ownership) who meet the specified criteria. For example, when 20% of the capital shares of a legal person belong to a Russian national and 20% to a natural person residing in Russia.

The initial information on such transfers is due to be submitted by 15.07.2024 for the first semester of 2024 (period from 01.01.2024 to 30.06.2024).

The aforementioned obligation is set out in Article 5r(2) of Regulation No 833/2014.

The purpose of Article 5r of Regulation No 833/2014 is to provide the competent authorities of a Member State with the necessary information to enable them to identify transactions, entities, and business sectors that indicate a serious risk of sanctions breaches, circumvention, or use of funds for purposes incompatible with the Regulation.

Considering the abovementioned, credit institutions and financial institutions are required to provide detailed information to the FIU that might be necessary to assess such risk, including information on the payer, the individual payments, the amount of each payment, information on the recipient of the payment, the credit institution of the recipient, the purpose of the payment, information on the transaction for which the payment is made (if available) and other related information.

Further information on the reporting obligation can be found in the replies prepared by the European Commission to the frequently asked questions here.

A template for submitting information is available for download here.

The information must be sent to the email address: sankcijas@fid.gov.lv.

Credit institutions have the obligation to inform the FIU of certain persons who are subject to EUR 100 000 deposit restriction by submitting the following information:

1. a list of deposits exceeding EUR 100 000 held by Russian nationals or natural persons residing in Russia or by legal persons, entities, or bodies established in Russia. Credit institutions shall provide updated information regarding the amounts of such deposits every 12 months starting from 27.05.2022;
2. a list of deposits exceeding EUR 100 000 held by a legal person, entity, or body established outside the European Union and whose proprietary rights are directly or indirectly owned for more than 50% by Russian nationals or natural persons residing in Russia. Credit institutions shall provide updated information regarding the amounts of such deposits every 12 months starting from 27.05.2023;
3. information on deposits exceeding EUR 100 000 held by Russian nationals or natural persons residing in Russia and who have acquired the citizenship of a Member State or residence rights in a Member State through an investor citizenship scheme or an investor residence scheme;
4. a list of deposits exceeding EUR 100 000 held by Belarusian nationals or natural persons residing in Belarus or by legal persons, entities, or bodies established in Belarus. Credit institutions shall provide updated information regarding the amounts of such deposits every 12 months starting from 27.05.2022;
5. information on deposits exceeding EUR 100 000 held by Belarusian nationals or natural persons residing in Belarus and who have acquired the citizenship of a Member State or residence rights in a Member State through an investor citizenship scheme or an investor residence scheme.

The aforementioned obligation is set out in Article 5g of Regulation No 833/2014 and Article 1z of Regulation No 765/2006.

The information should be provided using the template developed by the European Banking Authority available here.

When selling, supplying, transferring, or exporting sensitive goods and technologies as listed in Annexes XI, XX, and XXXV to Regulation No. 833/2014, common high-priority items as listed in Annex XL to Council Regulation No. 833/2014, or firearms and ammunition as listed in Annex I to Council Regulation (EU) No 258/2012 to a third country, other than the partner countries listed in Annex VIII to Council Regulation No 833/2014, 2exporters shall, as of 20.03.2024, contractually prohibit re-exportation to Russia and re-exportation for use in Russia..

Exporters shall ensure that the agreement with the third-country counterpart contains adequate remedies in the event of a breach of a contractual obligation concluded in accordance with these requirements.

This requirement shall not apply to the execution of contracts concluded before 19.12.2023 until 20.12.2024 or until their expiry date, whichever is earlier.

Exporters who are residents of Latvia or who are registered in Latvia have the obligation to inform the FIU as soon as they become aware of a breach by a third-country counterpart of any of the contractual obligations concluded in accordance with these requirements.

The aforementioned obligation is set out in Article 12g of Regulation No 833/2014.

The laws and regulations governing sanctions provide for various other specific cases when persons have the obligation to provide information to the competent authority in matters related to the implementation of sanctions. Regulation No 833/2014 (e.g. Article 2(3), Article 3b(4), Article 3m(11), etc.) and Regulation No 765/2006 (e.g. Article 1s(2), Article 1e(3), etc.) impose various obligations to provide different types of information which are not mentioned in this section of the website.

When persons in Latvia become obligated to provide information to the competent authority in accordance with the laws and regulations governing sanctions, they shall provide this information to the FIU.

In accordance with Section 17 of the Law on International Sanctions and National Sanctions of the Republic of Latvia, the persons under the supervision of the supervisory authorities referred to in Section 13 of the Law are obligated to immediately report to the FIU , in accordance with the procedure laid down in the Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing, if there are suspicions of a violation or an attempted violation of international and national sanctions.

Suspicious transaction report is to be submitted to the FIU:

1. via reporting system goAML;
2. by emailing to the FIU at pasts@fid.gov.lv;
3. at the FIU premises at 28 Vaļņu Street, Riga.

For clarification on the obligation to report violation or attempted violation of sanctions, please refer to the guidelines developed by the FIU “Reporting Suspicious Transactions and Refraining from Execution of Suspicious Transactions” (available in Latvian language).

In accordance with the Law on International Sanctions and National Sanctions of the Republic of Latvia, the FIU provides society with information and training on matters regarding the implementation of sanctions. In this regard, persons may submit an application to the FIU with questions related to the implementation of sanctions. Please note that under the current legislation, the FIU is not authorised to perform an official interpretation of legal provisions.

For information on how to submit an application, please refer to the section “Contacts”.