In view of Russia's aggression against Ukraine and the military attack on Ukraine, the European Union and other countries continue to step up sanctions against Russia and Belarus, which will also affect payments made and received to/from Russia and Belarus. We provide answers to frequently asked questions about the impact of sanctions against Russia and Belarus on payments and other financial transactions.
General questions on sanctions
The EU sanctions map developed by the EU may be used to search information: https://www.sanctionsmap.eu/. The tool provides information on the EU sanctions against the country concerned, legal and natural persons and restrictions on sectoral breakdown, as well as the legal framework in which the specific restrictions are contained. The sanctions list search tool is available on the website of the Financial Intelligence Unit (FIU): https://sankcijas.fid.gov.lv/. When searching for information with the FIU sanctions finder, please take into account: In addition, please use: https://www.fid.gov.lv/lv/aktualitates/sankcijas-biezak-uzdotie-jautajumi. Information on sanctions is also available on the website of the Ministry of Foreign Affairs: https://www.mfa.gov.lv/en/sanctions. Information on US OFAC sanctions is available at: https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctions-programs-and-information. Moreover, the US OFAC sanctions list search tool may be used: https://sanctionssearch.ofac.treas.gov/. Lursoft has established and maintains a common list of information on entities included in the sanctions lists of Latvia, the United Nations, the European Union, the United Kingdom and OFAC: https://sankcijas.lursoft.lv. The list shall be updated on a daily basis from the primary sources to ensure access to the current information and is available free of charge to anyone entrepreneur. Published: 23.03.2022 The European Commission has published and regularly supplements answers to the most frequently asked questions about the application of sanctions. The European Commission's replies are available in the section Frequently Asked Questions. General explanations on the application of European Union sanctions can also be found in the material "Restrictive measures (Sanctions) – Update of the EU Best Practices for the effective implementation of restrictive measures" prepared by the Working Party of the Foreign Relations Counsellors. Please note that these materials are general recommendations that are not complete and are designed to effectively implement European Union sanctions in accordance with applicable European Union and national law. The information material is available here. Published: 25.03.2022 Given that banks must ensure that sanctions are imposed and that the sanctions are very wide-ranging, they may have an impact on the timing of the assessment and and extend the processing and execution time of payment transactions. In situations where the payee is a client of the bank on the sanctions list, the payment will not be executed. In addition, sanctions imposed by the European Union are directly binding not only on the financial sector but also on any person, including entrepreneurs. Those entrepreneurs cooperating with Russia or Belarus need to follow up on the sanctions imposed and to evaluate their cooperation partners (including counterparty structure and beneficial owners) in order to decide on the feasible future cooperation, to avoid the involvement of the company in transactions with sanctioned persons. If the owner structure of counterparty is complicated and non-transparent, it is impossible to verify whether the beneficial owner is the right one, etc., then we recommend the termination of business relations with that counterparty. Companies should also take into account a ban on the in Russia (e.g., the sale, supply, transfer or export of dual-use items to any person in Russia or for the use in Russia are prohibited, as well as the sale, supply, transfer or export of goods and technologies related to the aviation sector) and Belarus (e.g., the EU has also imposed sectoral sanctions on the Belarusian oil, potassium and tobacco sectors). The movement of dual-use (strategic) goods is governed by the Law on the Circulation of Goods of Strategic Significance. Additional information on the circulation of strategic goods may be found here: In addition, the prohibition of the provision of technical assistance, directly or indirectly, intermediation services or other services related to goods and technology subject to prohibitions and the provision, production, maintenance and use of those goods and technologies should be assessed. Updated: 29.03.2022 The FCMC issued a general licence to credit institutions for individuals and legal entities. For legal entities, the licence provides for the coverage of business core costs to the extent that they are strictly necessary for the legal entity to continue to exist, such as taxes, State fees, compulsory State social insurance contributions. Updated: 01.08.2022 The consequences of the breach of sanctions may have a significant impact. In accordance with Section 84 of the Criminal Law, criminal liability is provided for the violation of sanctions imposed by the United Nations, the European Union and other international organizations or for the violation of national sanctions imposed by the Republic of Latvia. In addition, in accordance with the Law on International Sanctions and National Sanctions of the Republic of Latvia, certain persons have an obligation to carry out a risk assessment of sanctions and to establish an internal control system. According to Section 13.2 of the above Law, these persons may be subject to administrative sanctions for infringements in the field of international and national sanctions requirements. It should be also noted that the violation of sanctions or attempts to circumvent them may pose a risk to entrepreneurs not to receive services from Latvian financial institutions, as well as to have a significantly negative impact on the company's reputation, which may further cause problems in attracting new customers and partners for cooperation or negatively affect existing business relationships. Published: 16.03.2022
Financial services and restrictions imposed thereto
Payments/settlements
Banking payments to and from Russia and Belarus are not prohibited in general, but due to the heavy sanctions, banks have to carry out increased and time-consuming checks and therefore payments are burdened. We call on residents and entrepreneurs to be tolerant, as banks take measures to ensure that sanctions are actually enforced. When establishing any relationship with the sanctioned persons, the bank may refuse to carry out the transactions. There may also be situations where the bank does not want to take on the risk inherent to the counterparty of an individual customer in Russia and/or Belarus and therefore a specific transaction or further cooperation may be refused. Published: 04.03.2022 The payments received from Russia may be affected by imposed sanctions against Russian natural or legal entities, including Russian banks. The payments may also be affected by restrictions imposed by Russia on payments outside Russia’s territory. Published: 04.03.2022 Yes, it is possible, only it may take longer. Such option could be denied if Russia applies restrictions on currency transactions outside Russia's territory. Published: 04.03.2022 The determining factor is a residence permit, not the application of the tax regime. Published: 04.03.2022 Such questions should be addressed to your bank. Published: 04.03.2022 Payments received from Russia may be affected by sanctions imposed against Russian natural or legal entities, including Russian banks. Payments may also be affected by restrictions imposed by Russia on the payments outside Russia's territory. This applies to payments in any currency, not only in Russian roubles. Published: 04.03.2022
Transactions with payment cards (VISA, Master card)
In general, we recommend not relying on cards issued by Russian banks and have the cash needed for daily spending when travelling to Belarus or Russia (e.g., when travelling, truck drivers, seafarers). Published: 04.03.2022 In general, we recommend not relying on cards issued by Russian banks and have the cash needed for daily spending when travelling to Belarus or Russia (e.g., when travelling, truck drivers, seafarers). Published: 04.03.2022
Investment services and transactions in financial instruments
There are no restrictions on transactions on the Latvian securities market so far, while Latvijas Banka and the securities market organiser independently follow developments in the securities market, including cyber security. Restrictions related to sanctions, Moscow Stock Exchange and Russian-backed securities may be imposed on supervisors or market organisers by different countries (national exchanges), who carry out regular supervision of stock exchange members and stock exchange events. Please follow public sources with regard to the imposition of sanctions and the official information of your chosen national stock exchange and supervisory authority on additional restrictions on securities transactions. In addition, the sectoral restrictions introduced by the European Union against the Russian Federation, which prohibit financing or investment service transactions or their provision or trading in new bonds or equities or similar financial instruments, should be taken into account. Regulation: https://eur-lex.europa.eu/legal-content/LV/TXT/?uri=CELEX:02014R0833-20190709. Updated: 25.11.2022 Yes, in accordance with Council Decision (CFSP) 2022/327 of 25 February 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, the above restriction on deposits also applies to all products mentioned in the question. In addition, as from 9 March 2022, this type of restriction shall also apply to the products mentioned in the question concerning Belarus. In particular, pursuant to Council Decision (CFSP) 2022/399 of 9 March 2022 amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, it is prohibited to accept any deposits from Belarusian nationals or natural persons residing in Belarus, or legal persons, entities or bodies established in Belarus, if the total value of deposits of the natural or legal person, entity or body per credit institution exceeds EUR 100 000. Published: 16.03.2022
Imports and exports of goods (Russia, Belarus)
At present, there is no general ban on imports or exports of goods, but there are certain sectors and categories of goods for which any exports and/or imports of goods to Russia or Belarus are prohibited. More detailed information on specific categories of goods and technology can be found in the relevant EU Regulations, which include prohibitions on exports and/or imports of goods and technology. Also, persons are prohibited from purchasing goods or receiving services from natural and legal persons subject to sanctions that provide for the freezing of funds and economic resources and the prohibition to transfer funds and economic resources to sanctioned persons. Persons are also prohibited from purchasing goods or receiving services from persons who are owned or controlled by persons on the sanctions lists. In addition, the logistical conditions of the moment have to be taken into account. The airspace of several countries has been closed and the supply of goods may be problematic. It should also be noted that there are ever-new sanctions that may change the conditions in the future. Published: 16.03.2022 On 16.03.2022, the European Commission published replies to the most frequently asked questions relating to the export restrictions on dual-use goods and technologies laid down in Articles 2, 2a and 2b 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. The published material can help companies to understand and apply the new export restrictions, which complement and extend the previous framework for controlling exports of dual-use products to Russia. The answers to the most frequently asked questions published by the European Commission are available here. Published: 25.03.2022
For third-country nationals (citizens of Russia, Belarus)
Sanctions are imposed on certain natural and legal persons, including Russian credit institutions, without being universally applied to all citizens of the Russian Federation. Meanwhile, transactions involving citizens of the Russian Federation could face disruptions if they are customers of a sanctioned credit institution or they engage in transactions with a credit institution included on the sanctions list or conduct unauthorised transactions prohibited by the imposed sanctions. In response to Russia's aggression in Ukraine, new sanctions are being imposed. Published: 04.03.2022, updated 11.04.2024 In cash in euro or using a payment card issued by a bank other than a bank of the Russian Federation. It is not possible to settle accounts outside the Russian Federation with a payment card issued by the bank of the Russian Federation. Published 11.03.2022 Money can be transferred through the companies that provide remittance services, including several banks that are not sanctioned. It should be noted that Russia has imposed restrictions on the payments outside Russia's territory. Published 11.03.2022 Russia has imposed restrictions on payments outside Russia's territory. Currently, a Russian resident may transfer a maximum of USD 5000 or equivalent in another currency per month to a person in Latvia. Published 11.03.2022 The freeze will only be carried out in cases where a natural person is on the sanctions list. If a natural person is included in the sanctions lists, the accounts of natural persons and legal persons under their control will be frozen. Published: 04.03.2022 The inclusion of a person in the sanctions list does not depend on the person's citizenship. Published: 04.03.2022 This is most directly related to whether or not the bank which is being used for pension payments is included in the sanctions list. Pensions are among the basic needs covered by the general license of the FCMC. If the money comes to Latvian banks, pensions will be paid. In cases where money transfers take place between several countries, a long review process in other countries should be taken into consideration as well as that this cash flow may be suspended. Latvijas Banka will also work with foreign counterparts to avoid sanctions against those who do not have to suffer. Published: 04.03.2022, updated 25.11.2022 This is not a question within Latvijas Banka's competence and it is difficult to comment on this issue at the moment because there are many unknown factors: (1) whether the responsible authorities of Russia will do everything to use financial institutions that are not on the sanctions list, (2) what the reaction of correspondent banks will be and whether they will be able to influence the process, (3) what support will be provided to the Latvian state institutions if finding a solution takes more time. Published: 04.03.2022, updated 25.11.2022