22.05.2026 11:49
Key Sanctions Developments in Q1 2026
SUMMARY EU is strengthening sanctions against Russia, including banning the import of petroleum products produced from Russian crude oil and approving a gradual phase-out of Russian natural gas.Krievijas dabasgāzes.EU is expanding sanctions lists in response to human rights violations and Russia’s destabilising activities.The Court of Justice of the European Union confirms broader application of sanctions to companies and prohibits sanctioned persons from participating in shareholders’ meetings.In Latvia, 24 new criminal proceedings have been initiated for violations of international sanctions.Latvian courts completed adjudication in 11 sanctions-related cases, with several resulting in fines and imprisonment.The Customs Board of the State Revenue Service initiated 29 administrative offence proceedings.Guidance on the application of sanctions has been updated. Strengthening of SanctionsOn 21 January, a ban entered into force in the European Union (EU) on the import of petroleum products manufactured from Russian crude oil.¹ Although the EU had already prohibited imports of Russian crude oil (except via pipelines), it had until now remained permissible to import petroleum products manufactured in third countries using Russian crude oil.On 26 January, a regulation was adopted approving the EU’s gradual phase-out of Russian natural gas.² The import ban entered into force on 18 March, while transitional periods for the fulfilment of existing contracts will remain in place until the end of 2027. Specific exemptions are also предусмотрены for landlocked countries.Although the 20th sanctions package was adopted on 23 April, during the first months of the year the EU expanded sanctions regimes targeting Russia’s “hybrid warfare”³ activities and human rights violations. On 23 February, the EU imposed sanctions on eight Russian individuals for serious human rights abuses and acts of repression. In addition, the sanctions list related to Russia’s destabilising activities was expanded by 10 individuals, primarily authors and distributors of Russian propaganda.Key Judgments of the Court of Justice of the European UnionOn 26 March, the Court of Justice of the European Union dismissed appeals submitted by five sanctioned individuals — Dmitry Alexandrovich Pumpyanskiy, Tigran Khudaverdyan, Viktor Filippovich Rashnikov, Dmitry Arkadievich Mazepin, and German Khan — who sought the annulment of sanctions imposed against them.⁵ The joined cases are particularly significant because the Court interpreted the criterion of an “influential businessperson” for inclusion on sanctions lists. The Court confirmed that a person may justifiably be sanctioned even without direct links to the Russian government if the individual is economically influential or operates in a sector constituting a substantial source of revenue for the Russian government.Additional important sanctions-related judgments were delivered on 12 March. The Court confirmed⁶ that the assets of a company owned or controlled by a sanctioned person may also be frozen even if the company itself is not listed under sanctions, provided that at least 50% of its shares are owned by a sanctioned individual.In another judgment,⁷ the Court ruled that persons included on sanctions lists are not permitted to participate in shareholders’ meetings or exercise voting rights therein.FIU TopicalitiesDuring the first quarter, the Financial Intelligence Unit of Latvia received 310 suspicious transaction reports indicating possible sanctions violations or attempted violations. Most reports concerned the possible shipment of prohibited goods to Russia through third countries, the provision of services to Russian companies, accounts held in sanctioned banks, and the transportation of cash to Russia. A total of 51 analytical reports relating to possible sanctions violations were forwarded to law enforcement and other authorities.On 20 February, the FIU adopted a new General Authorisation, expanding the categories of payments for which sanctioned persons no longer require separate FIU permission.The FIU also repeatedly updated the “Frequently Asked Questions” section of its website regarding sanctions implementation, clarifying existing guidance and adding new questions. New explanations were provided, for example, regarding the provision of services to Russian and Belarusian companies, the obligation to comply with EU sanctions in third countries, the holding of shares in Russia or Belarus, framework agreements, the transit of goods through the EU, and the FIU General Authorisation.By the end of the first quarter of 2026, the following assets owned or controlled by sanctioned persons had been frozen in Latvian financial institutions and state registers: funds — EUR 152.2 millionreal estate properties — 103vehicles — 66agricultural machinery — 11vessel — 1livestock herd — 1trademarks — 12 A list of sanctioned persons with frozen assets in Latvia is available here.Criminal Proceedings Statistics in LatviaDuring the first quarter of 2026:24 new criminal proceedings were initiated for violations of international sanctions;criminal prosecution was commenced in six criminal proceedings;charges were brought against seven natural persons;five criminal proceedings were referred to court;two criminal proceedings were completed through prosecutorial penalty orders.In one of the proceedings concluded through a prosecutorial penalty order, a natural person was fined EUR 9,360, while a legal entity was ordered to pay more than EUR 17,100. The case concerned an attempt to export sanctioned goods — primer products valued at EUR 67,800 — to Russia using falsified documents and falsely declaring Kazakhstan as the final destination. The goods had already been confiscated, sold, and the proceeds transferred to the state budget.In another criminal proceeding concluded through a prosecutorial penalty order, a Russian citizen holding a permanent residence permit in Latvia was placed under probation supervision for three years. In this case, the individual knowingly violated EU sanctions against the Russian Federation for financial gain by remotely working as a programmer (1C developer) for a Russia-registered company and thereby systematically providing prohibited IT consultancy services. Between 2022 and 2025, the individual received remuneration amounting to 5.89 million Russian roubles (approximately EUR 64,200). Part of this remuneration — nearly EUR 10,000 — was received through an account held with a sanctioned bank, thereby directly making funds available to a sanctioned legal entity.In Latvian CourtsDuring the first months of the year, Latvian courts completed adjudication in 11 criminal cases related to sanctions violations.In one case, a judgment entered into force imposing fines exceeding EUR 26,500 on two individuals. In two other cases, criminal proceedings were terminated after the court concluded that no criminal offence had occurred.A further six individuals were convicted in cases where judgments had not yet entered into force by the end of the quarter. In two cases, imprisonment sentences of 11 years⁸ and three years respectively were imposed. The largest fine imposed on a natural person amounted to EUR 31,200, while the largest monetary recovery ordered against a legal entity amounted to EUR 39,000.Customs Board TopicalitiesThe Customs Administration of the State Revenue Service of Latvia initiated 29 administrative offence proceedings related to sanctions violations.Overall, during the reporting period, 187 consignments were denied border crossing due to sanctions violations or suspicions of sanctions circumvention. Most rejected consignments concerned exports. The most frequently blocked exports included spare parts for various devices and machinery, electrical equipment and components, and vehicle spare parts. Imports from Russia and Belarus involving construction structures, timber, iron compounds, and furniture were also denied.In an additional 43 cases, attempts were identified to export cash denominated in official EU Member State currencies from the EU in violation of sanctions regulations. Postal controls prevented 31 violations, while 42 cases involved individuals attempting to transport sanctioned goods across the border.Example of a Sanctions ViolationOn 23 January 2026, at the Pāternieki Customs Control Point, customs officials identified an attempt to transport engines to Belarus. Although the declared recipient was located in Kazakhstan, the engines in question were also prohibited from transit through Russia and Belarus. The total value of the goods amounted to EUR 102,000. Criminal proceedings were initiated in connection with the case. Photos by Customs Board About the Quarterly PublicationThe Financial Intelligence Unit of Latvia publishes quarterly summaries of key sanctions-related developments and statistics in order to provide the public with regular and transparent information regarding sanctions updates and their enforcement in Latvia. The publication is based on information available to the FIU, as well as data provided by the Prosecutor General’s Office, the Court Administration, and the Customs Administration of the State Revenue Service. 1The prohibition is set out in Article 3m of Council of the European Union Council Regulation (EU) No 833/2014: https://eur-lex.europa.eu/legal-content/EN/AUTO/?uri=celex:32025R1494. 2https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202600261. 3https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02024R2642-20260316. 4https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02024R1485-20260223. 5Judgment in joined cases C-696/23 P, C-704/23 P, C-711/23 P, C-35/24 P and C-111/24 P: https://eur-lex.europa.eu/legal-content/LV/TXT/HTML/?uri=CELEX:62023CJ0696. 6 Judgment in case C-84/24: https://eur-lex.europa.eu/legal-content/LV/TXT/HTML/?uri=CELEX:62024CJ0084. 7 Judgment in case C‑465/24: https://eur-lex.europa.eu/legal-content/LV/TXT/HTML/?uri=CELEX:62024CJ0465. 8 In the case, violation of sanctions was one of the criminal offences with which the person had been charged. The term of imprisonment was reduced to 9 years, 8 months and 29 days, applying Section 52 of the Criminal Law.
