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Confirming Latvia's unwavering commitment to improving national and regional sanctions systems, as well as promoting international dialogue in the field of sanctions, the Financial Intelligence Unit (FIU) invites you to watch a live conference on industry news on November 6, 2025. The seventh annual conference “Guarding the Gate: Sanctions, Export Controls & Business Responsibilities” will provide in-depth insights into sanctions policy trends, judicial and supervisory practice, and corporate compliance strategies. The impact of sanctions on the economy and Latvia’s experience in sanctions enforcement will also be discussed. The conference will bring together experts in the field of sanctions in person and online. Experts in the field will share their experience at the conference, such as Baiba Braže, Minister of Foreign Affairs of the Republic of Latvia, John E. Smith, former Director of the US Office of Foreign Assets Control (OFAC), Tom Keatinge, Director of the Center for Security and Finance at the Royal United Services Institute (RUSI), Laila Medina, Advocate General of the Court of Justice of the European Union, Benjamin Hilgenstock, Head of the Macroeconomic Research and Strategy Department at the Kiev School of Economics, and other experts from EU Member States, the United Kingdom, Canada, and the United States. Conference agenda Main topics: Sanctions and security policy for the realization of strategic goals.The role of courts in shaping sanctions policy.Border security - the role of customs and export control.Sanctions violation investigation: specific cases and consequences of violations.Enforcement of sanctions in practice: the role and responsibility of businesses.Tracking cash flows: risks and responsibilities in the financial sector.The price of sanctions: impact on the Russian and global economies.Guarding Europe's external borders: Latvia's experience. The conference will be held in English with simultaneous translation into Latvian. If you have any questions, please contact us by e-mail: conferences@fid.gov.lv.

The European Union (EU) member states have agreed to strengthen restrictive measures against the aggressor state Russia and its supporter Belarus, adopting the 19th sanctions package on October 23, 2025. The new round of sanctions will significantly affect Russia's energy sector, imposing a ban on the import of liquefied natural gas, the financial sector, restricting the issuance of payment instruments, and the shadow fleet, including 116 new shadow fleet vessels on the sanctions list. Key elements of the 19th round of sanctions The list of goods and technologies subject to export bans has been expanded to include goods that can be used to develop Russia's military capabilities. Goods that, due to their physical and chemical properties, can be used to develop Russia's military and defense capabilities, as well as be used in hostilities in Ukraine, include, for example, military rangefinders or various chemical alloys and metals used in the production of electronic devices, the export of which to Russia is prohibited. Ban on the import of liquefied natural gas (LNG) In order to negatively impact one of Russia's most profitable sectors, namely restricting the flow of electricity resources, the new round of sanctions imposes a ban on the purchase, import, and transportation of liquefied natural gas of Russian origin (or exported from Russia) from January 1, 2027. Stricter restrictions on cashless transactions Similar to the SPFS system created by the Central Bank of Russia, which was created in response to Russia's exclusion from the SWIFT network, the 19th round of sanctions prohibits transactions with certain persons using Mir (the Russian national payment card system) and SBP (Fast Payment System), which were created by the Central Bank of Russia or another legal entity registered in Russia. Measures to restrict crypto asset transactions Recognizing the risks that may arise from the use of crypto-assets to circumvent sanctions and finance war, EU Member States have decided to add to the list of transaction prohibitions those third-country financial institutions that provide services related to crypto-assets. Prohibition on issuing payment instruments The new round of sanctions prohibits the EU from issuing payment instruments to Russian nationals or natural persons residing in Russia, or to any legal person, entity or body established in Russia. A payment instrument is understood to be any personalised device and/or set of procedures agreed upon between a payment service user and a payment service provider and used to initiate a payment order. Potential, the development of which can contribute to Russia's military capabilities – SEZ ban Special economic zones, or SEZs, attract new companies with favorable tax rates, customs exemptions and other advantages for legal entities. Several such SEZs are located in different regions of Russia. The economic activities that take place in them can serve Russia's technological and industrial development, for example, unmanned aerial vehicles, combat weapons, military vehicles and other equipment that can be used for military purposes are produced under legally and economically favorable conditions. Recognizing the potential risks that attracting new companies to SEZs can pose, thereby strengthening Russia's military capabilities, sanctions prohibit any kind of involvement in the ownership structures of companies located in certain Russian SEZs, including establishing joint ventures, as well as concluding any kind of contracts with such companies. Prohibition of the provision of artificial intelligence, quantum computing and commercial space services In view of the rapid development of technologies, especially in the field of information technology, new restrictions have been imposed on the provision of services to persons registered in Russia in the following areas: artificial intelligence, commercial space services and quantum computing. The provision of such services can be used in the interests of Russia to develop its skills and technological solutions in geological exploration and the creation of precise geographical maps. Russia as an undesirable tourist destination In order to reduce the number of non-essential trips by EU citizens to Russia, the provision of tourism services to persons wishing to visit Russia on tourist trips is being restricted. Given that EU Member States are undesirable for Russia, citizens of Member States risk their freedom, which may be restricted under Russian jurisdiction. In such cases, EU Member States have limited diplomatic and consular possibilities to release their citizens and bring them to EU territory. The provision of services requires authorization from the competent authority. For the provision of such services (which are not prohibited) to Russian authorities, it will be mandatory to obtain a permit from the competent authority of the Member State. Before providing a specific service, the service provider will need to justify the need for this service. If the competent authority of the Member State decides to grant a permit after a thorough assessment of this justification, a permit will be issued on the basis of which the specific service may be provided. Prohibition of reinsurance for Russian aircraft and ships To reduce financial gain from selling old, unmaintained and unused aircraft and ships owned by Russia, it is prohibited to reinsure them for five years from the date of sale. Extended deadline for transactions to ensure the closure of companies owned by EU nationals in Russia Legal and natural persons of EU Member States with registered companies in Russia are being granted an extension of the deadline of 31 December 2026 for transactions related to the disposal or liquidation of these companies in Russia. The EU Member States reiterate that Russia is a country outside the rule of law, therefore, no reaction from Russia is foreseeable and decisions have been issued in relation to companies whose owners are from “undesirable countries”, including the European Union. This may lead to the risk of freezing the assets of such companies in Russia and other adverse actions against such companies. In particular, the EU calls for careful consideration and assessment of all possible risks for citizens of Member States who are considering establishing companies or joint ventures in Russia. Stricter travel restrictions for Russian diplomats A prior notification requirement is introduced for Russian diplomats and consular officials entering the Schengen area and Member States other than their Member States of accreditation. Member States will now have the right to prohibit Russian diplomats from entering their territory on the basis of entry documents issued by another country. List of partner countries for oil imports expanded The list of partner countries from which proof of origin is not required for imports of petroleum products, in accordance with Article 3ma of Regulation (EU) 833/2014 and Annex LI thereto, has been expanded to include Australia, Japan and New Zealand, in order to promote cooperation and energy security in Europe. EU sanctions lists have been supplemented with: 45 legal entities that support the Russian defense and security sector, including legal entities from third countries;eight credit institutions with which it is prohibited to engage in any transactions;116 “shadow fleet” ships or vessels, four ships removed from the list;four banks outside Russia that use the SPFS of the Central Bank of Russia, established by the Central Bank of Russia;six financial institutions that provide crypto-asset services;11 special economic zones (SEZs) , in which it is not permitted to be a participant, establish a new joint venture, entity or structure, as well as conclude contracts for the purchase of goods or services with a legal entity registered in one of the listed SEZs;one cryptoasset. Targeted financial sanctions set new definitions for the terms: “owned” and “controlled” The definition of the above-mentioned terms will strengthen legal certainty and uniform practice in the EU Member States. Until now, the EU institutions have explained these terms in the form of guidelines. Now the terms have been incorporated into the regulations and become legally binding. It is important to emphasize that the definitions incorporated in the regulation correspond to the definitions previously explained by the EU institutions, therefore the practice of applying the terms will remain unchanged. New definitions have been established in Article 1 of Regulation (EU) 833/2014 for the following terms: “crypto -asset”“payment services”The reference to “related parties” in Article 2 of Regulation (EU) 269/2014 has been removed . Annex I to Regulation (EU) 269/2014 may further include persons involved in criminal offences against Ukrainian children and their assimilation in the interests of Russia, including deportation, forcible transfer and Impact of the 19th round of sanctions on Belarus In order to avoid the risk of possible circumvention of sanctions through Belarus, the elements of the 19th round of sanctions are also applicable to Belarus. Almost all of the above-mentioned prohibitions or restrictions, for example, in connection with the addition of new goods that can be used for the development of the military sector to the export ban list, restrictions on the provision of artificial intelligence services, restrictions on transactions using crypto assets, etc. Additionally, restrictions have been imposed related to the provision of computer software development, installation and maintenance services. A more detailed summary of the 19th round of sanctions. More information about the new round of sanctions is available in the Official Journal of the EU . To help entrepreneurs develop and implement a set of measures, or internal control system (ICS), to mitigate and manage sanctions risks in transactions with merchants in countries with increased sanctions risk, the FID has published guidelines “Managing Sanctions Risks in Transactions with Increased Risk Countries”. Since April 2024, the FID has been the national competent authority for sanctions enforcement issues in Latvia.

The United Nations Security Council (UNSC) has decided to renew several sanctions regimes against Iran, originally imposed in 2006 to stop the country's potential development of nuclear weapons, from 28 September 2025. The sanctions were suspended in 2015, but on 25 August this year, Britain, France and Germany informed the UNSC of Iran's material non-fulfillment of its obligations. This gave Iran 30 days to find a diplomatic solution and prevent the sanctions from being reinstated - a deadline that expired a week ago. The renewed sanctions include six UN Security Council resolutions: No. 1696 (2006) requires Iran to suspend all uranium enrichment-related activities and prohibits other countries from transferring missile technology to Iran;No. 1737 (2006) prohibits the transfer of proliferation-related technology to Iran, and imposes an asset freeze and travel restrictions on proliferation-related individuals and entities. Currently, sanctions target 43 individuals and 78 entities ;No. 1747 (2007) adds to the list of sanctioned entities and imposes financing restrictions on Iran;No. 1803 (2008) adds to the list of sanctioned entities and strengthens control measures to more effectively monitor the implementation of sanctions;No. 1835 (2008) confirms commitment to sanctions;Resolution 1929 (2010) imposes comprehensive sanctions, including a complete arms embargo and a ban on Iran investing in the development of foreign missile technology. Additional information is also available on the website of the Ministry of Foreign Affairs. In accordance with the first paragraph of Article 11 of the Law on International and National Sanctions of the Republic of Latvia, sanctions imposed by resolutions of the United Nations Security Council and sanctions imposed by European Union regulations are binding and directly applicable in the Republic of Latvia.

Paulis Iļjenkovs, Deputy Head of the Financial Intelligence Unit (FIU) for Sanctions, spoke at a public hearing of the European Parliament's Committee on Economic and Monetary Affairs (ECON) on the implementation and effectiveness of European Union (EU) financial sanctions against Russia. The discussion was also attended by John Berrigan, Director-General for Financial Stability, Financial Services and Capital Markets Union of the European Commission. "Currently in force, financial sanctions are strong, but member states need to improve their implementation in practice. Without a more uniform application of sanctions, their impact on Russia will be less than possible," emphasized Paulis Iļjenkovs. Photo: from left: John Berrigan, Director-General of the European Commission for Financial Stability, Financial Services and Capital Markets Union, and Paulis Iļjenkovs, Deputy Head of the Financial Intelligence Unit for Sanctions. In his speech, the FIU representative emphasized three important aspects: The EU's financial sanctions against Russia are strong and influential – they include an asset freeze of approximately €25 billion, the immobilization of the Russian Central Bank's reserves of approximately €210 billion, as well as capital market restrictions, transaction bans and other measures.Their impact directly depends on a unified and coordinated implementation. Latvia has established a centralized approach: unified sanctions enforcement, a verified register of frozen assets, close monitoring of payments and trade flows, extensive guidelines for entrepreneurs, and already around 600 criminal proceedings, mostly for violations of trade sanctions.Regularly assess which financial sanctions are most effective and focus the activities of customs, financial intelligence units, law enforcement and compliance teams on those areas where results are strongest. The discussion also raised the risks of circumventing sanctions, including through third countries and cryptocurrencies. P. Iļjenkovs pointed out that, thanks to the EU's 19th sanctions package, it is also possible to target cryptocurrency service providers located outside the EU that help Russia evade sanctions. The possibility of using frozen Russian assets as collateral for loans to Ukraine was also discussed, as well as strengthening measures to confiscate funds related to criminal activities of Russian oligarchs. More information and a recording of the discussion can be found here.

From September 13, 2025, the Cabinet of Ministers' regulation will enter into force, which determine the framework of Latvia's national sanctions regime and define the criteria on the basis of which it is possible to impose national sanctions on specific individuals and legal entities related to the Russian Federation's military aggression against Ukraine. The Financial Intelligence Unit (FIU) invites you to familiarize yourself with the information on what these regulations provide for and how they will be applied in practice. Within the framework of the national sanctions of the Republic of Latvia, the government may impose financial and entry restrictions provided for in the Law on International and National Sanctions of the Republic of Latvia against entities that are not subject to international sanctions and that meet the specific criteria. For example, the aforementioned restrictions may be imposed against entities that are influential businessmen operating in the Russian Federation, or against individuals and legal entities operating in economic sectors that provide a significant source of income for the Russian Federation. The FIU explains that the Latvian national financial sanctions framework is essentially in line with the targeted financial sanctions imposed by the European Union. This means that when imposing national financial sanctions, the funds and any other economic resources of a person are frozen, as well as a prohibition is imposed on making funds or economic resources available. This essentially means that it is prohibited to directly or indirectly carry out any transactions with persons subject to financial sanctions. The Ministry of Foreign Affairs of the Republic of Latvia explains that, as the Russian Federation's aggression against Ukraine continues, it is necessary to promote the effectiveness of Latvia's sanctions policy and to provide for the possibility of imposing national sanctions against entities that are directly or indirectly involved or have been involved in supporting the Russian Federation's military aggression against Ukraine and cause or may cause harm to Latvia's national security. The FIU reminds that every person has an obligation to immediately report to the FIU about the implementation of international and national sanctions, including any freezing of funds or economic resources. This means that if a person is included in the Latvian national sanctions list and their funds or economic resources are frozen, the FIU must be immediately informed about this. More information about reporting obligations is available in the section “Information to be submitted to the FIU”. On September 12, 2025, the Cabinet of Ministers adopted the Cabinet Regulations “Regulations on the Determination of National Sanctions of the Republic of Latvia against Entities Related to the Military Aggression of the Russian Federation against Ukraine” (available in Latvian language) at an extraordinary meeting . This is an additional instrument with which, in the current geopolitical situation, it is possible to respond to threats to Latvia's national security caused by Russian aggression. The Regulations entered into force on September 13, 2025. They also provide for exceptional cases in the implementation of sanctions, when the FIU may make a decision on the application of exceptions, i.e. a decision on the issuance of a permit. At the same time, we inform you that on September 12, 2025, the Council of the European Union unanimously decided to extend until March 15, 2026 the restrictive measures directed against persons responsible for undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. Sanctions lists and other useful information available on the FIU website . Since April 2024, the FIU has been the national competent authority for sanctions enforcement issues in Latvia.

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.

A significant precedent has been established in Latvia regarding the enforcement of sanctions: the Administrative District Court has rejected an application by a legal entity registered in Latvia to be removed from the list of sanctioned entities maintained by the Financial Intelligence Unit (FIU). The legal entity is 50% indirectly owned by a person included on the sanctions list. In rejecting the claim for compensation of more than one million euros, the court concluded that the actions of the involved authorities in publishing information about the applicant on the sanctions list were lawful. Similarly, no direct causal link was found between the authorities’ actions and the claimant’s inability to settle its obligations, as a result of which enforcement proceedings were directed against a helicopter owned by the claimant. “This ruling is a significant step toward strengthening Latvian case law regarding the enforcement of sanctions. It clearly confirms that a 50% ownership stake in a legal entity is sufficient grounds to freeze the assets of such a legal entity that is not included on the list. It is significant that the court confirms the need to interpret the element of control broadly in order to prevent the circumvention of sanctions. This ensures that attempts by sanctioned persons to transfer assets using front persons, trusts, or shell companies, as well as other attempts to evade the application of sanctions, are unsuccessful,” explains Marta Tilhena, Head of the Sanctions Implementation Division at the FIU. In accordance with European Union (EU) legislation and best practices, a 50% ownership stake is sufficient to apply the same restrictions to a person not directly included on the sanctions list be subject to the same restrictions as a person included on the list, including the freezing of funds and economic resources. Consequently, the FIU's action — in determining the justification for freezing the applicant’s assets and including them on the FIU's list of sanctioned entities—was deemed lawful in this case. The court, citing provisions of the Commercial Law, noted that ownership of 50% of the shares or equity interests also enables one to determine the composition of the board of directors, influence or block the company’s decisions, and control the use of funds and resources, which fully corresponds to the element of control within the meaning of the EU sanctions regime. A broad interpretation of the element of control is necessary to prevent the circumvention of sanctions. The Court draws attention to the real-world situation in which assets can be transferred within a short period of time, and therefore has identified ways in which a listed person may exercise control over an unlisted entity (e.g., majority ownership, use of front persons, use of trusts, shell companies, and limited liability companies). 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.

The Financial Intelligence Unit (FIU) has prepared informational material explaining the most important European Union sanctions restrictions that must be observed in the Republic of Latvia. The material is publicly available and may be freely used and distributed to raise awareness about the significance of sanctions, the main restrictions, and other important information. Sankciju ievērošana Latvijas Republikā Sanctions compliance in the Republic of Latvia which sanctions are in force in Latvia and who must comply with them;what legal consequences may result from violating sanctions;what services are prohibited for Russian and Belarusian companies and the government;with whom cooperation is prohibited (individuals, companies, banks);which import and export transactions with Russia and Belarus are prohibited;what to do if there is suspicion of a sanctions violation. In addition, the FIU has published guidelines titled “Sanctions risk management for business in heightened-risk countries”, to help businesses develop and implement a set of measures, or an internal control system (ICS), to mitigate and manage sanctions risks in transactions with businesses in heightened-risk countries. Please note that this informational material does not replace legal advice. Sanctions may be expanded or amended, so we encourage you to regularly check the latest information on the FIU website: https://sankcijas.fid.gov.lv

On July 18,2025, the member states of the European Union (EU) agreed to impose the 18th packageof sanctions against Russia. These sanctions impose stricter measuresparticularly in the energy and finance sectors. The Financial Intelligence Unit(FIU) urges close monitoring of changes in the sanctions regulations andemphasizes that it is especially important to ensure compliance among businessesinvolved in exports and international trade. Key elementsof the 18th round of sanctions: Lowered pricecap for Russian oil A new Oil PriceCap mechanism has been established, reducing the existing price ceiling andallowing the price ceiling to be reviewed regularly in accordance with theaverage market price of oil. Currently, the cap has been lowered by 15%, from60 to 47.6 USD per barrel. Ban on NordStream pipelines The EU isintroducing a complete prohibition on transactions related to the Nord Stream 1and Nord Stream 2 pipelines. This means that no EU operator will be permittedto engage in either direct or indirect transactions concerning the completion,operation, maintenance, or use of these pipelines. The ban also extends to thepurchase of natural gas if it is supplied via these pipelines. Prohibitionon the import of refined petroleum products The EU hasimplemented a ban on importing refined petroleum products produced from Russiancrude oil. This means that EU Member States will also be prohibited fromimporting such products from third countries if they are manufactured usingcrude oil of Russian origin. Expanded listof Russian “Shadow Fleet” vessels The sanctionslist has been expanded with an additional 105 “shadow fleet” vessels thatprovide Russia with revenue to finance the war against Ukraine. In total,sanctions now apply to 447 vessels that transport Russian oil using risky andcovert delivery methods. Stricter financialsector restrictions Previousrestrictions regarding the use of the SWIFT system by certain Russian bankshave been converted into a full ban on transactions. In addition, the list ofbanks with which transactions are prohibited has been expanded by 22 newRussian credit institutions. Furthermore,a transaction ban has been imposed on several banks outside Russia that use thefinancial messaging system SPFS created by the Central Bank of Russia. In thisway, Russia is seeking to reduce the impact of the disconnection of Russianbanks from the SWIFT system. Expanded sanctionslists An additional41 legal entities have been included in the sanctions list for providingsupport to the Russian military-industrial complex in the war against Ukraine,as well as for supplying goods and technologies that develop Russia’s militarysector. Simultaneously, the targeted financial sanctions list has been expandedwith 14 individuals. Under thesanctions regime targeting human rights violations in Russia, sanctions havebeen imposed on five Russian judges involved in serious human rights abuses andin carrying out repression against civil society and the democratic opposition. Meanwhile,under the sanctions regime addressing Russia’s destabilising activities in theEU and globally, a third package has been adopted, adding nine individuals andsix legal entities responsible for conducting foreign information manipulationand interference. SanctionsAgainst Belarus Eight legalentities linked to the military industry and arms production have been added tothe sanctions list. The Belarus sanctions regime has also been expanded toalign it with the sanctions imposed on Russia, including extended import andexport bans, an expanded list of goods and technologies prohibited from transitthrough Belarus, and a ban on transactions with certain Belarusian creditinstitutions and companies. SanctionsAgainst the Destabilization of Moldova Sevenindividuals and three legal entities have been added to the sanctions regimetargeting the destabilization of Moldova for activities directed against the stateof Moldova, including attempts to influence the 2024 presidential elections.The legal entities included in the sanctions list are located in Russia, whileamong the individuals, six hold Moldovan citizenship and one holds Russiancitizenship. More detailedinformation on the new package of sanctions is available in the OfficialJournal of the European Union. To supportentrepreneurs in developing and implementing a set of measures a.k.a. aninternal control system (ICS) for mitigating and managing sanctions-relatedrisks in transactions with businesses in heightened-risk countries, the FIU haspublished guidelines "Sanctions risk management for business inheightened-risk countries". Sanctionslists and other useful information are available on the FIU’s official website. From April 2024, the FIU is the national competentauthority in matters related to the sanctions implementation.