The Financial Intelligence Unit of Latvia (FIU) informs that in accordance with the regulatory framework of the sanctions imposed against Russia, legal entities incorporated in Latvia shall, as of 1 May, report to the FIU any transfer of funds exceeding EUR 100,000 out of the Union that they made during that quarter, directly or indirectly, in one or several operations if the proprietary rights are directly or indirectly owned for more than 40% by:
The reporting obligation also applies to legal persons for which the 40% ownership threshold is reached by several persons together. For example, 20% of the capital is owned by a legal entity incorporated in Russia and 20% by a natural person residing in Russia.
The first report, due by 15 May, must include information on payments made by legal persons between 1 January and 31 March of this year. From the second quarter onwards, the report will have to be submitted within two weeks of the end of each quarter.
The aim of the regulatory framework is to provide competent authorities with more information on flows of funds between the European Union and third countries, allowing them to identify sectors with a high risk of sanctions evasion and to identify sources of Russian revenue.
Credit institutions and financial institutions are required to submit reports on transfers made out of the Union by customers that meet the abovementioned conditions on a semi-annual basis as of 1 July for the period from 1 January to 30 June of this year.
The template to be used for submitting the report is available on the website of the FIU under section Information to be submitted to the FIU. The report must include information on the payment, the payee, the ownership structure of the legal entity and its compliance with the reporting obligation criteria, and other information specified in the template. Information should be sent to the e-mail sankcijas@fid.gov.lv.
Additional information on the reporting requirement is available at Information to be submitted to the FIU and the explanatory notes prepared by the European Commission are available here (in English).
The reporting obligation is laid down by Article 5r of Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.