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New decision on payments allowed in sanctions implementation without separate authorisation from FIU Latvia
02.01.2025.

The general authorisation of the Financial and Capital Markets Commission which became effective on 27 July 2022 and has been applied until now will expire on 31 December 2024. The general authorisation allows financial institutions to make payments related to the provision of basic needs or basic business expenses of a sanctioned person. In order to ensure continuity in the implementation of sanctions, the Financial Intelligence Unit of Latvia (FIU) has issued a new general administrative act “Regarding Determination of Authorised Payments” which will enter into force on 1 January 2025.

The decision aims to ensure that persons not targeted by international sanctions against the Russian Federation and the Republic of Belarus are not influenced by them unduly. At the same time, it reduces the administrative burden for payees whose transactions with sanctioned persons have an objective legal basis.

The new decision taken by the FIU clarifies the types of payments and applies to sanctioned persons, credit and financial institutions, as well as sworn bailiffs and service providers.

Main regulations

  1. The FIU has listed the categories of payments which may be made by sanctioned persons without a separate authorisation for a sanctions exemption;
  2. Payments are to be made to credit and financial institutions registered in the Republic of Latvia in accordance with the specified conditions;
  3. Individual payments above the limits will require individual authorisation from FIU Latvia;
  4. In the course of their duties, sworn bailiffs will be able to make certain payments without additional authorisations.

Payment categories

The decision defines payment categories for both natural and legal persons. These include, but are not limited to:

  1. payments for basic daily needs (e.g. food, utilities, medicine);
  2. taxes and mandatory State fees;
  3. rent and mortgage payments (provided the contracts were signed before the sanctions were imposed);
  4. payments for routine holding of the frozen economic resources.

Reporting obligation

Sanctioned persons and sworn bailiffs will be required to submit quarterly reports to the FIU on the payments made. These reports must be submitted within two weeks following the end of the quarter, together with supporting documents.

For more information, see General licence.

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