On 29th of April, representatives of the Financial Intelligence Unit of Latvia participated in the ninth high-level meeting organised by the European Commission on the implementation of European Union (EU) restrictive measures. During the meeting, representatives of EU Member States, the European Commission, the European External Action Service and partner countries discussed the effectiveness of sanctions regimes, current trends in sanctions violations, as well as opportunities to strengthen a unified approach to sanctions implementation and prevent sanctions breaches.

The meeting was chaired by Commissioner for Financial Services and the Savings and Investments Union Maria Luís Albuquerque.

“Such formats of international cooperation are important for building a common understanding of sanctions risks, promoting information exchange, and strengthening practical cooperation among EU Member States and international partners. Effective sanctions implementation is an essential prerequisite for ensuring European security and the rule of law,” emphasised Marta Tilhena.

Particular attention was devoted to the recently adopted 20th sanctions package, including the first-ever application of the EU anti-circumvention instrument. In response to increasing trade flows of high-priority goods to certain third countries and potential sanctions circumvention risks, the EU introduced a prohibition on the export of specific goods to the Kyrgyz Republic. The measures aim to reduce the risk that such goods could be re-exported to Russia and used for the needs of its military-industrial complex.

The meeting also addressed issues related to restrictions on Russian energy exports, the activities of the so-called “shadow fleet,” the use of alternative payment networks in third countries, and the impact of sanctions on Russia’s ability to finance warfare. Participants discussed the latest trends and typologies of sanctions violations, as well as effective solutions for preventing and investigating sanctions breaches.

At the same time, the importance of the EU’s international dialogue with third countries was highlighted. Discussions included examples where financial institutions and supervisory authorities in third countries introduced significant improvements in sanctions risk management following the imposition of EU sanctions. In certain cases, after assessing the effectiveness and sustainability of these improvements, financial institutions were subsequently removed from EU sanctions lists.

Member States also shared practical experience in sanctions enforcement and investigations of sanctions violations, including the detention and seizure of “shadow fleet” vessels, as well as criminal proceedings in cases where sanctioned goods had been attempted to be delivered to Russia through third countries.

Following the high-level meeting, the Sanctions Coordinators Forum took place under the leadership of EU Sanctions Envoy David O’Sullivan. Representatives from Ukraine, the United Kingdom, the United States and other partner countries also participated in the forum, discussing the impact of sanctions and strengthening future international cooperation.

During the meetings, the importance of intelligence-sharing and interinstitutional cooperation in effective sanctions implementation was also emphasised, alongside the need to continue close cooperation with third countries and the private sector in sanctions risk management.

Since April 2024, the Financial Intelligence Unit of Latvia has been the national competent authority for sanctions implementation.