To help businesses develop and implement a set of measures for mitigating and managing sanctions risks in dealing with operators in high-risk sanctions countries, otherwise called an internal control system (ICS), the Financial Intelligence Unit (FIU) has published the guidelines “Sanctions risk management for business in heightened-risk countries”.
Heightened-risk sanctions countries are those that do not impose sanctions against Russia and Belarus and which, due to their geographic location or other reasons, are used to circumvent the restrictions set out in sanction regulations, for example, delivering sanctioned goods to Russia or Belarus.
The guidelines include explanation on:
The guidelines were developed by the FIU in cooperation with the Finance Latvia Association, Latvijas Banka, the Customs Board of the State Revenue Service, the Ministry of Foreign Affairs, and the Employers’ Confederation of Latvia. The guidelines are designed to help manage sanctions risks related to the EU sanctions against Russia and Belarus, however, they can also be used in the broader context of other sanctions risks.
Exporters of high-priority goods can apply these guidelines to fulfil their obligation under sanctions regimes to develop and implement an ICS for mitigating and effectively managing sanctions risks.
The guidelines currently are available in Latvian language here and will soon be available in English language in section "Guidelines".