The Financial Intelligence Unit (FIU), together with the Customs Administration of the State Revenue Service, calls on exporters to pay special attention to the risks identified by the European Union (EU) related to the export of common high priority goods 1 to third countries. These are goods that, bypassing EU sanctions, end up in Russia or Belarus and are used for military purposes.
The common list of high-priority goods includes goods and technologies that are important for the development, production, use of Russian military goods or that have been found in Russian weapons used in Ukraine. The EU sanctions framework provides for prohibitions and additional obligations for persons involved in the circulation of common high-priority goods.
The aim of these bans is to ensure that Russia does not have access to critical technologies and to weaken its industrial base, thereby limiting the aggressor state's ability to wage war in Ukraine. The responsible Latvian authorities are intensifying their monitoring of the circulation of such goods and the effectiveness of the enforcement of the related sanctions regulations.
The EU sanctions framework imposes certain prohibitions and obligations on persons involved in the circulation of high-priority goods. They apply not only to the sale, supply and export, but also to the transportation, loading and transhipment of goods. Therefore, the prohibitions also apply in cases where the goods are not imported into the EU, but only transported between a third country and Russia or Belarus. Economic operators must comply with these prohibitions at all times – regardless of where the export of the goods begins and whether the goods cross the territory of the EU.
We would like to inform you that the FID has developed and published guidelines "Managing Sanctions Risks in Transactions with High-Risk Countries" to help entrepreneurs gain an understanding of how to develop and implement a set of measures or internal control system (ICS) to mitigate and manage sanctions risks when conducting transactions with business partners in high-risk countries, especially transactions related to goods or services subject to sanctions.
Exporters of common high-priority goods can use these guidelines to meet their obligation under the sanctions framework2 to develop and implement an ICS to mitigate and effectively manage sanctions risks. It should be noted that exporters of common high-priority goods must implement and apply ICS measures to all transactions, not just transactions with counterparties in high-risk countries.
Main prohibitions and obligations:
Prohibition on direct or indirect export to Russia, Belarus and certain persons associated with the military and industrial sector, as well as transit ban: common high priority items shall be prohibited from being sold, supplied, transferred or exported, directly or indirectly, to any natural or legal person, entity or body in Russia or Belarus, or for use in Russia or Belarus, regardless of whether they are goods and technology originating in the EU or not. The transit of these items through the territory of Russia and Belarus is prohibited.3 These items shall also be prohibited from being sold, supplied, transferred or exported, directly or indirectly, to certain persons outside Russia and Belarus who are military end-users, who are part of the Russian or Belarusian military and industrial complex or who have commercial or other links to the Russian defence and security sector, or who otherwise support the Russian defence and security sector.4
The obligation to take steps to identify risks associated with the entry of goods into Russia and Belarus and to implement appropriate policies, controls and procedures to mitigate these risks:
take appropriate measures, proportionate to their nature and scale, to identify and assess the risks associated with the export of high-priority goods or technologies to Russia and Belarus, and for use in Russia and Belarus, and ensure that those risk assessments are documented and updated;
appropriate policies, controls and procedures, proportionate to their nature and scale, must be implemented to mitigate and effectively manage the risks associated with the export of high-priority goods or technologies to Russia and Belarus, and exports for use in Russia and Belarus, regardless of whether those risks are identified at the level of the Member State or the EU.5
Obligation to contractually prohibit re-export of goods to Russia and Belarus, and re-export for use in Russia and Belarus: exporters, when selling, supplying, transferring or exporting high-priority goods to a third country, shall prohibit re-export to Russia and Belarus, and re-export for use in Russia and Belarus, ensuring that the agreement with the third-country counterparty provides for appropriate legal remedies in the event of a breach of the re-export ban. Persons in Latvia must immediately inform the FID of the fact that a third-country counterparty has breached the re-export ban.6
Obligation to contractually prohibit the transfer of intellectual property rights and trade secrets to Russia or for use in Russia: when selling, licensing or otherwise transferring intellectual property rights or trade secrets, as well as granting the right to access or reuse any material or information protected by intellectual property rights or as a trade secret and related to the joint high-priority goods, the third-country partners must contractually prohibit their third-country partners from using such intellectual property rights, trade secrets or other information in connection with the joint high-priority goods intended to be sold, supplied, transferred or exported directly or indirectly to Russia or for use in Russia, and require the third-country partners to prohibit potential sub-licensees of such intellectual property rights or trade secrets from using such intellectual property rights, trade secrets or other information. The agreement with the third-country counterparty must provide for appropriate legal remedies in the event of a breach of the aforementioned prohibition on the transfer of intellectual property. Persons in Latvia must immediately inform the FID of the fact that a third-country counterparty has violated the aforementioned transfer prohibition.7
Obligation to obtain a permit for the export of goods to a third country, if the Export Control Division of the Ministry of Foreign Affairs of Strategic Importance has informed the exporter of the aforementioned obligation: with amendments that entered into force on 20 July 2025, the EU sanctions regulation introduced a requirement to obtain a permit for the export of goods and technologies that could contribute to the increase of the military and technological capacity of Russia or Belarus or the development of the defense and security sector to any third country, if the competent authority of the Member State in which the exporter is resident or established has informed the exporter of the aforementioned requirement. 8
High Priority Items List (Excel)
Since April 2024, the FID has been the national competent authority for sanctions enforcement issues in Latvia.
1 Common high priority items are listed in Annex XL to 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); and in Annex XXX to Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine (Regulation No 765/2006).
2 Article 12gb of Regulation No. 833/2014, Article 8ga of Regulation No. 765/2006.
3 In accordance with Article 2a of Regulation No 833/2014 and Article 1f of Regulation No 765/2006.
4 In accordance with Article 2b of Regulation No 833/2014 and Article 1fa of Regulation No 765/2006. The list of persons who are military end-users, who are part of the Russian or Belarusian military-industrial complex or who have commercial or other links to the Russian defence and security sector, or who otherwise support the Russian defence and security sector, is set out in Annex IV to Regulation No 833/2014 and Annex V to Regulation No 765/2006.
5 Article 12gb of Regulation No. 833/2014, Article 8ga of Regulation No. 765/2006.
6 Article 12g of Regulation No 833/2014, Article 8g of Regulation No 765/2006. Further information: “https://finance.ec.europa.eu/publications/no-re-export-russia-clause_en”
7 Article 12ga of Regulation No. 833/2014.
8 Article 2a(1aa) of Regulation No 833/2014, Article 1f(1aa) of Regulation No 765/2006.
