On Tuesday, 10 June 2025, significant amendments will enter into force in Latvia regarding liability for the violation of international sanctions. The amendments provide for tougher criminal penalties, a new administrative liability mechanism and simplified reporting on violations of international sanctions. These legislative changes strengthen national efforts to effectively prosecute the violators of international sanctions.

“As a European Union Member State, Latvia has the duty to ensure that any violations of sanctions are subject to effective, proportionate and deterrent penalties. By strengthening the framework of penalties for serious offences, while at the same time introducing administrative liability for minor violations, a noteworthy step has been made for enhancing the efficiency of all authorities involved in preventing sanctions violations as well as investigating and prosecuting such offences. This holds particular significance given Russia’s continuing aggressive war against Ukraine”, says Juris Stukāns, Prosecutor General of the Republic of Latvia.

“These are significant changes aimed primarily at deterring potential sanctions violations and also making the process of investigation and prosecution quicker and more efficient. At the same time, criminal liability has been retained for the violation of financial sanctions as well as for offences linked to goods and services that support the continuation of Russia’s military aggression against Ukraine,” as explained by Deputy Head of the Financial Intelligence Unit of Latvia (FIU), Paulis Iļjenkovs.

Tougher penalties for sanctions violations

Section 84 of the Criminal Law introduces new qualifying elements of a criminal offence and also extends the maximum limits for custodial sentence thereby making it possible to impose stricter penalties for sanctions violations.

Criminal liability will apply to actions involving goods and related services that are subject to sanctions, provided that the violation of sanctions is committed on a significant scale, specifically, the value of the goods or services is not less than EUR 10 000.

At the same time, the existing threshold for criminal liability in cases of violations involving goods of strategic importance, firearms and their essential components, ammunition for firearms, goods or technology intended for military purposes, and also other objects of sectoral or targeted financial sanctions, has been maintained.

Administrative liability for minor violations

The Law on International Sanctions and National Sanctions of the Republic of Latvia has been supplemented with additional provisions, thus establishing administrative liability in cases where the terms of sanctions have been violated through the purchase, sale or movement of sanctioned goods across the national border of the Republic of Latvia or through the provision of brokering services, technical assistance or any other services involving these goods, or through any other prohibited action involving these goods, provided that the value of the goods or services is below EUR 10 000.

Fines of up to EUR 10 000 and EUR 30 000 may be imposed on natural persons and legal persons respectively.

This approach will simplify and enhance the handling of violations that do not create high levels of harm, while also ensuring the confiscation of goods subject to sanctions and deterring individuals from committing offences in the future.

Simplified reporting procedures

The amendments have simplified the procedures for reporting on violations of international and national sanctions (including circumvention, which is a form of sanctions violation) or attempted violations of international and national sanctions by designating a single authority, the Financial Intelligence Unit of Latvia, to which reports should be submitted.

Based on these amendments, the Financial Intelligence Unit of Latvia has updated its Guidelines on Reporting Suspicious Transactions and Refraining from Execution of Suspicious Transactions, which will be published on the website of the Financial Intelligence Unit of Latvia available at: https://fid.gov.lv/en/roles-and-responsibilities/strategic-analysis-and-guidelines. 

Amendments have been made to the Law on International Sanctions and National Sanctions of the Republic of Latvia, the Criminal Law, and the law On the Procedures for the Coming into Force and Application of the Criminal Law, thus ensuring the transposition of Directive (EU) 2024/1226 of the European Parliament and of the European Council of 24 April 2024 on the definition of criminal offences and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673.