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In Case C-109/23 Jemerak, the Court of Justice of the European Union (Court) ruled that authentication of a purchase contract by a sworn notary does not constitute a legal advisory service within the meaning of Article 5n(2) 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 (Regulation No 833/2014) because the sworn notary is performing his or her statutory duties. In its judgment, the Court points out that the actions performed by a sworn notary in order to execute an authenticated real estate purchase contract (e.g., transfer or purchase contract fee to the seller’s account) do not constitute a legal advisory service within the meaning of Article 5n(2) of Regulation (EU) No 833/2014. In addition, the Court points out that the prohibition in Article 5n(2) of Regulation No 833/2014 on the provision of legal advice to legal persons incorporated in the Russian Federation does not apply to interpreting services provided by an interpreter during certification to assist a representative of a legal person incorporated in the Russian Federation who is not fluent in the national language of the certification procedure. The judgment of the Court of Justice of the European Union is available here: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A62023CJ0109

On September 12, 2024, the Parliament of the Republic of Latvia passed amendments to the Road Traffic Law (Law1), prohibiting vehicles registered in the Republic of Belarus from participating in road traffic within the territory of the Republic of Latvia. By adopting these amendments, the legislature aligned these restrictions with the existing prohibition on vehicles registered in the Russian Federation from participating in road traffic. The Law provides only two derogations under which the Financial Intelligence Unit may grant authorization for entry into the European Union with a vehicle registered in the Republic of Belarus, when crossing the border of the Republic of Latvia: A person with mobility impairments driving their own specially equipped vehicle registered in the Republic of Belarus may enter for the purpose of visiting a spouse or a direct-line relative residing in the Republic of Latvia;The Minister of Foreign Affairs may request that an application for entry into the Republic of Latvia be considered in special cases related to national interests. The derogations outlined in the Law comply with the restrictions specified in Article 1ra(1) and the derogations specified in Article 1ra(5) of Council Regulation (EC) No 765/2006 of 18 May 2006, concerning restrictive measures in view of the situation in Belarus and Belarus' involvement in the Russian aggression against Ukraine.2 This means that authorizations for entry into the European Union by crossing the border between the Republic of Latvia and the Republic of Belarus will only be granted by the Financial Intelligence Unit in the cases specified by the Law. Applications that do not meet the legal criteria will not be considered by the Financial Intelligence Unit. Authorizations for entry into the European Union by crossing the border between the Republic of Latvia and the Republic of Belarus, which have already been granted by the Financial Intelligence Unit, will remain valid until their specified expiration date. New authorizations will be issued by the Financial Intelligence Unit only in the cases outlined by the Law. The amendments to the Law stipulate that vehicles registered in the Republic of Belarus, which are already in the territory of the Republic of Latvia, must leave the country or be registered in accordance with regulatory procedures no later than October 31, 2024. If these actions are not taken within the specified time period, the vehicle will be confiscated in accordance with the provisions of the Law. 1 Available: https://titania.saeima.lv/LIVS14/saeimalivs14.nsf/webSasaiste?OpenView&restricttocategory=691/Lp14 2 Available: https://eur-lex.europa.eu/legal-content/LV/TXT/?uri=CELEX%3A02006R0765-20240701

In accordance with the Law on International and National Sanctions of the Republic of Latvia, the Financial Intelligence Unit (FIU) publishes on its website information received from persons on sanctioned persons whose funds and economic resources whose funds and economic resources are frozen in Latvia. Pursuant to Section 23 of the Regulation of the Cabinet of Ministers No 184 “Procedures for the Proposition and Implementation of International and National Sanctions", within 30 days after the publication of the information, the FIU shall assess whether the implementation of sanctions was carried out in accordance with the applicable laws and regulations. In total, by 31.07.2024, the FIU has concluded, as a result of assessment, that the freezing of funds and economic resources of 31 persons has not been carried out in accordance with the requirements of the laws and regulations governing sanctions: #Name and Registration NumberCountry of RegistrationDate of the FIU verification1AS "Euro Rail Trans", registration No 40103520476Latvia03.06.20242SIA "MARITIME REGISTER OF SHIPPING" registration No 40003250467Latvia03.06.20243SIA “Anulatrans”, registration No 40003431947Latvia03.06.20244INTERGRAIN S.A., registration No B175745Luksemburga03.06.20245JSC Tander, registration No 2310031475Russia03.06.20246MARITIME REGISTER OF SHIPPING (UK) LTD, registration No 03222610United Kingdom03.06.20247PHOSAGRO TRADING SA, registration No CHE-107.384.794Switzerland03.06.20248TOSHKENT METALLURGIYA ZAVODI, registration No 304574612Uzbekistan03.06.20249MAARSCHALL GROUP B.V., registration No 8182316Netherlands11.06.202410LEGION AO, registration No 1065003027462Russia11.06.202411SKYVEST TRADING LIMITED, registration No HE269979Cyprus11.06.202412GRUPPA KOMPANII SPIRTNOI OOO, registration No 1157746437793Russia11.06.202413ATLANT INC, registration No 100010198Belarus27.06.202414BELARUSIAN UNIVERSAL COMMODITY EXCHANGE OJSC, registration No 190542056Belarus27.06.202415BELGOSSTRAKH, registration No 100122726Belarus27.06.202416Belintertrans Baltic UAB, registration No 302513951Lithuania27.06.202417Belintertrans-Germany GmbH, registration No HRB 12382Germany27.06.202418BELPOCHTA RUE, registration No 101015738Belarus21.06.202419BTLC STATE ENTERPRISE, registration No 191184235Belarus27.06.202420Byelpromimpeks JSC, registration No 100088681Belarus27.06.202421VITEBSKOBLAVTOTRANS OOO, registration No 300029557Belarus27.06.202422NZGA OAO, registration No 500235715Belarus03.07.202423RUE BELTELECOM, registration No 101007741Belarus03.07.202424RUE HMC BELARUSIAN GLASS COMPANY, registration No 591035628Belarus11.07.202425PAPER MILL OF GOZNAK UE, registration No 600017868Belarus11.07.202426JSC RUCHAIKA, registration No 200048573Belarus11.07.202427OAO GRONITEKS, registration No 500046539Belarus11.07.202428INTER RAO UES PJSC, registration No 2320109650 shares in a security account of a non-sanctioned natural person*Russia11.07.202429SANATORIJA BELORUS VIESOJI ISTAIGA, registration No 110070044Lithuania31.07.202430Foundation “Riga Jurmala Music Festival”, registration No 40008283962Latvia31.07.202431RFCL S.AR.L., registration No B176899Luksemburga31.07.2024 * The FIU determined that the freezing of INTER RAO UES PJSC shares in the securities account of a non-sanctioned natural person was not justified, because shares owned by the natural person are not considered to be owned, controlled or held by INTER RAO UES PJSC and therefore are not subject to the asset freezing obligation. At the same time, the FIU would like to point out that in accordance with the assessment of the FIU, INTER RAO UES PJSC is considered to be a sanctioned person, because it is controlled by sanctioned persons (Igor Ivanovich SECHIN, Dmitry Evgenevich SHUGAEV). Information on sanctioned persons whose funds or economic resources are frozen in Latvia is maintained in the data tables published by the FIU until FIU receives information that the frozen funds or economic resources of the sanctioned person have been released from freezing, for example, based on a binding decision issued by the FIU. Information on all sanctioned persons whose funds or economic resources are frozen in Latvia, including cases where in accordance with the assessment of the FIU, the freezing of funds or economic resources is not justified and the funds or economic resources should be released from freezing, is available on the website https://sankcijas.fid.gov.lv/en/sanctioned-persons.

The Financial Intelligence Unit of Latvia has published the methodological material “Indicators of Sectoral and Targeted Financial Sanctions Evasion”. This methodological material is an updated version of the 2022 guidance material “Indicators of Russia-Related Sanctions Evasion”. Since Russia’s war of aggression against Ukraine began on 24 February 2022, the EU has imposed extensive and unprecedented sanctions against Russia, with a total of 14 rounds of sanctions adopted at the time of creating this material. Individuals are increasingly looking for new ways to breach or circumvent sanctions. Thus, this updated material includes up-to-date information on the sanctions framework, including the extended sanctions against Belarus, information on newly identified typologies of sanctions evasion, as well as information on trends of trade flows. The methodological material has been developed in cooperation with the Office of the Prosecutor of the Republic of Latvia, the State Security Service, Latvijas Banka, Tax and Customs Police Department of the State Revenue Service, National Customs Board of the State Revenue Service, and seven Latvian credit institutions, i.e. Swedbank AS, Luminor Bank AS Latvian Branch, SEB banka AS, Citadele banka AS, BluOr Bank AS, Rietumu Banka AS, Signet Bank AS. Individuals are encouraged to familiarise themselves with the updated material and to use it for risk-based sanctions compliance. “Indicators of Sectoral and Targeted Financial Sanctions Evasion”

In view of the involvement of the Republic of Belarus in the unprovoked and unjustified war brought by the Russian Federation against Ukraine, on 29 June 2024, the Council of the European Union imposed additional restrictive measures targeting the Belarusian economy. These restrictive measures are aimed at imposing sanctions that are already imposed against the Russian Federation, thereby limiting the evasion of sanctions imposed against the Russian Federation as a result of the high degree of integration between the Russian and Belarusian economies. The new sanctions include trade restrictions, a ban on the supply of certain services, restrictions on transport and logistics, and also anti-circumvention measures that will affect various sectors of the Belarusian economy. Briefly on the essentials. Anti-circumvention measures: European Union exporters have the obligation to include in their future contracts a “Belarus exclusion clause” prohibiting the re-export to the Republic of Belarus or re-export for use in the Republic of Belarus of common high priority items and technology, firearms and ammunition. In addition, European Union exporters have to make sure that their subsidiaries also comply with the “Belarus exclusion clause”;The obligation for European Union exporters exporting common high priority items to third countries other than those listed in Annex Vba to Regulation (EU) No 765/2006 to put in place a risk-appropriate control mechanism that can identify, assess, and mitigate the risks associated with the export of these items to the Republic of Belarus. In addition, European Union exporters have to make sure that their subsidiaries also comply with the abovementioned obligation. The transit of the following goods through the territory of the Republic of Belarus shall be prohibited: Dual-use goods and technology, goods and technology which could contribute to the strengthening of the military and technological capacity of the Republic of Belarus or to the development of its defence and security sector;Goods which could contribute in particular to improving the industrial capacity of the Republic of Belarus (Annex XIX to Regulation (EU) No 765/2006);Transit through the territory of the Republic of Belarus of goods and technology suitable for use in aviation or the space industry and firearms exported from the European Union (Annex XVII to Regulation (EU) No 765/2006);Firearms and ammunition exported from the European Union, regardless of their origin. Import/export measures: Gold originating in Belarus and exported from the Republic of Belarus to the European Union or to any third country after 1 July 2024 (gold listed in Annex XXI to Regulation (EU) No 765/2006);Diamonds, if they originate in the Republic of Belarus or are exported from the Republic of Belarus to the European Union or any third country (diamonds and products incorporating diamonds listed in Parts A, B, and C of Annex XXIX to Regulation (EU) No 765/2006);Mineral products, if they originate in the Republic of Belarus or are exported from the Republic of Belarus (listed in Annex VII to Regulation (EU) No 765/2006).Crude oil products, if they originate in the Republic of Belarus or are exported from the Republic of Belarus (listed in Annex XXIII to Regulation (EU) No 765/2006);Goods which allow the Republic of Belarus to diversify its sources of revenue (e.g. coal, helium, etc.) if these goods originate in the Republic of Belarus or are exported from the Republic of Belarus (listed in Annex XXVII to Regulation (EU) No 765/2006). Restrictions on services: Prohibition to provide the following services to the Republic of Belarus, its government, its public authorities, corporations, or agencies, or any natural or legal person, entity or body acting on their behalf or at their direction: accounting services;auditing, including statutory audit services;bookkeeping services;tax consulting services;business and management consulting services;public relations services. Logistics/transport measures: Prohibition on the carriage of goods within the territory of the European Union by means of trailers or semi-trailers registered in the Republic of Belarus, including if the tractors of such trailers or semi-trailers are trucks registered in other countries;Prohibition of European Union companies registered after 8 April 2022 whereof 25% or more is owned by a natural or legal person of the Republic of Belarus from carrying out road haulage operations in the European Union, including in transit. Financial measures: It is prohibited to acquire new or extend existing participation in any legal person, entity, or body incorporated or constituted under the laws of the Republic of Belarus or any third country and operating in the energy sector in the Republic of Belarus;Introduction of the possibility for companies established in the European Union to create a “firewall” to ensure that a sanctioned entity that controls or owns a company established in the European Union does not benefit in any way, thus allowing the respective company to continue its business. Measures to protect European Union companies: Natural and legal persons of the European Union Member States shall be allowed to receive compensation from natural and legal persons of the Republic of Belarus for damage caused to them.

Global geopolitical events and technological developments have had an impact on the terrorism financing and proliferation financing (TF and PF) situation in Europe and Latvia. It has become more dynamic and complex. In the light of the evolving situation in the field of TF and PF, the Financial Intelligence Unit (FIU), in cooperation with the State Security Service (VDD), has developed updated Guidelines on the Prevention of Terrorism and Proliferation Financing. This is an updated version of the “TF and PF Prevention Guidelines for the Subjects of the Law on PMLTPF and Supervisory Authorities” developed by the FIU and the VDD in 2019. The updated guidelines are intended to serve as a practical tool for the subjects of the Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing (Prevention Law) and their supervisory and control authorities in planning and implementing measures to prevent TF and PF. The guidelines are designed to help financial institutions and other involved parties better understand, identify, and respond to potential TF and PF risks. The updated guidelines include a general description of TF and PF, the current situation and trends in Europe and Latvia, as well as detailed information on the signs that could indicate suspicious transactions involving TF and PF. The updated guidelines are part of a broader effort to strengthen the capacity of the Latvian financial market, including the ability of financial market participants and others involved in TF and PF prevention to mitigate and effectively manage TF and PF risks. The FIU stresses the importance of cooperation between the public and private sectors in order to ensure effective control and monitoring through joint efforts. Private and public sector representatives are invited to familiarise themselves with the updated guidelines and use them to improve TF and PF risk management systems in order to promote a safer financial environment in Latvia. Guidelines on the Prevention of Terrorism and Proliferation Financing

On 24 June 2024, the 14th set of restrictive measures against the Russian Federation was adopted. Briefly on the essentials in the 14th sanctions package. Energy-related measures: The package prohibits reloading services, including ancillary services, in the European Union for transhipment operations where such services are used for the transhipment of liquefied natural gas (LNG) originating in the Russian Federation or exported from the Russian Federation, except when such transhipment takes place to Member States;Prohibition of new investment and the supply of goods, technology, and services to complete LNG projects such as Arctic LNG 2 and Murmansk LNG. Anti-circumvention measures: European Union parent companies must make every effort to ensure that their subsidiaries in third countries do not participate in sanctions evasion;EU natural and legal persons selling sensitive goods and technologies as listed in Regulation (EU) No 833/2014 to third countries must have in place risk-appropriate control mechanisms capable of identifying and mitigating possible re-exports of goods to the Russian Federation;European Union natural and legal persons are required to contractually prohibit their counterparties in third countries from using or allowing the use of information protected by intellectual property rights or as trade secrets and transferred to them in connection with common high priority items to be sold, supplied, or exported to the Russian Federation or for use in the Russian Federation. Financial measures: European Union legal persons operating outside the Russian Federation are prohibited from connecting directly to the SPFS (the Russian Federation’s equivalent of SWIFT) or equivalent specialised financial messaging systems established by the Central Bank of Russia;European Union legal persons are prohibited from conducting business with respect to certain listed entities that use the SPFS outside the Russian Federation. The abovementioned measures do not apply to legal persons established and operating in the Russian Federation, including subsidiaries of European Union legal persons;Political parties, foundations, associations, non-governmental organisations, including think tanks, and media service providers in the European Union are prohibited from accepting, directly or indirectly, funding, donations, or any other economic benefit or support from the Russian Federation. Logistics/transport measures: Banned access to ports and locks of European Union Member States, as well as a ban on provision of a wide range of maritime transport services for specific vessels contributing to Russia’s warfare against Ukraine (targeting the shadow fleet);Additional restrictions are introduced on scheduled and non-scheduled flights where Russian Federation persons may determine the place or time of take-off or landing (including holidays and business meetings);Broadened prohibition on the transport of goods by road within the territory of the European Union, including in transit, so as to cover European Union companies which are owned 25% or more by a natural or legal person of the Russian Federation. Import/export measures: Imposed export restrictions on an additional 61 items supporting the military and industrial complex of the Russian Federation in its war of aggression against Ukraine, located in various countries including China, Kazakhstan, Kyrgyzstan, Turkey, and the United Arab Emirates;Additional restrictions are imposed on the export of goods that could contribute in particular to the enhancement of the Russian Federation’s industrial capabilities, e.g. chemicals, including manganese ores and compounds of rare-earths, as well as plastics, excavating machinery, monitors, and electrical equipment. In addition, five common high priority items were added to the export restrictions;Further restrictions are imposed on the import of helium, which is a source of significant revenues for the Russian Federation, allowing it to continue its war of aggression against Ukraine;Prohibition to acquire, import, transfer, or export Ukrainian cultural objects and other goods of archaeological, historical, cultural, rare scientific, or religious importance where there are reasonable grounds to suspect that the goods have been illegally removed from Ukraine. A ban on the provision of related services has been introduced in addition. Measures protecting intellectual property rights: Restrictions on accepting applications for the registration of certain intellectual property rights in the European Union submitted by natural and legal persons of the Russian Federation. Amendments regarding diamonds: It is clarified that the ban does not encompass diamonds that were physically located either within the European Union or in a third country, or were polished or manufactured in such third country, before the entry into force of the Russian Federation diamond ban;Temporary import or export of jewellery for auctions and repairs is allowed;The transitional period after which traceability scheme for diamonds will become mandatory is extended by 6 months (until 1 March 2025);It is stipulated that the indirect import ban on Russian Federation diamonds processed in third countries other than the Russian Federation temporarily will not apply to jewellery containing such diamonds until otherwise decided by the Council, taking into account the action taken within the G7 to implement the abovementioned measure. The latest sanctions impose restrictive measures against additional 116 natural and legal persons responsible for acts that undermine or threaten the territorial integrity, sovereignty, and independence of Ukraine. The listed persons are subject to an asset freeze and are prohibited from making funds available to citizens and companies of the European Union. Furthermore, natural and legal persons of the European Union Member States are allowed to receive compensation from natural and legal persons of the Russian Federation for damage caused to them. It is also prohibited to carry out transactions with persons listed in Annex XLIII to Regulation (EU) No 833/2014 who apply the Arbitration Procedural Code of the Russian Federation in order to settle claims under foreign jurisdiction. Publications in the Official Journal of the EU: https://eur-lex.europa.eu/legal-content/LV/TXT/HTML/?uri=OJ:L_202401745 (amendments to Regulation (EU) No 833/2014);https://eur-lex.europa.eu/legal-content/LV/TXT/HTML/?uri=OJ:L_202401739 (amendments to Regulation (EU) No 269/2014).

Directive (EU) 2024/1226 of the European Parliament and of the Council of 24 April 2024 on the definition of criminal offences and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673 (Directive) which enters into force on 19 May 2024 has been published in the Official Journal of the European Union. Until now, European Union Member States have had different practices in relation to the prosecution of those responsible for the violation of sanctions, including no obligation of Member States to criminalise such behaviour. The Directive provides for certain actions which will constitute a criminal offence and for which both natural and legal persons will be held criminally liable, e.g. violation of the prohibition imposed by the European Union to make funds or economic resources available, directly or indirectly, to or for the benefit of an entity or body subject to sanctions, conducting business with sanctioned persons, circumventing the travel restrictions imposed by the European Union, and other acts referred to in Article 3 of the Directive. Also, in order to ensure a proportionate use of investigative resources, taking into account the seriousness of the committed offence, the Directive provides that in certain cases Member States will be able to establish that infringements of restrictive measures of the European Union do not constitute a criminal offence if they concern goods, services, transactions, or activities of a value of less than EUR 10,000, and in such case the person may be held administratively liable. The Directive provides for various types of penalties for infringements of the regulatory framework on sanctions, including deprivation of liberty. The Directive will facilitate and unify the process of investigating and prosecuting infringements of the regulatory framework across the European Union. Latvia already criminalises violations of international and national sanctions, while, like other European Union Member States, Latvia will have to assess the compliance of its national regulatory framework with the Directive and transpose the Directive into national law by 20 May 2025.

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: a legal person, entity or body established in Russia;a Russian national; ora natural person residing in Russia. 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.