On 12 December 2025, the Administrative District Court (Court) rejected the application of a legal entity to remove it from the list of sanctioned entities maintained by the Financial Intelligence Unit (FIU). The Court found that the FIU's actual actions in this case were justified and lawful. At the same time, it should be noted that the judgment is a first instance decision and may be appealed in accordance with the procedure established by law.
In its judgment, the court assessed whether the criteria of ownership and control in relation to a person included in the European Union (EU) sanctions list were met in relation to the applicant.
This Court's judgment confirms the FID's practice in enforcing sanctions and contributes to mitigating the risks of sanctions circumvention.
The Court concluded that, in accordance with the EU sanctions framework and best practices, the applicant is subject to restrictive measures. In the opinion of the FID, the applicant is indirectly owned by an undertaking controlled by a person included in the sanctions list, therefore such an undertaking is considered to be an entity controlled by a person included in the sanctions list, whose funds and economic resources are subject to freezing. The Court has found the FID's conclusions to be well-founded.
FID recalls that the EU Targeted Financial Sanctions Regulation, as amended by the 19th sanctions package, contains definitions for the terms “ownership” and “control”.1
The definition of the aforementioned terms strengthens legal certainty and promotes uniform practice in the EU Member States, making these terms legally binding. It is important to emphasize that the definitions incorporated in the regulation correspond to the definitions explained in EU best practices, thus the basic principles of the application of the terms have been preserved unchanged in practice.
Sanctions lists and other useful information available on the FIU website.
Since April 2024, the FIU has been the national competent authority for sanctions implementation in Latvia.
1 Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine Article 1(i) and (j)