Court upholds FIU Latvia assessment on the application of EU sanctions

18.12.2025

On 12 December 2025, the Administrative District Court (the Court) dismissed an application submitted by a legal person seeking its removal from the list of sanctioned subjects maintained by the Financial Intelligence Unit (FIU Latvia). The Court found that FIU Latvia’s actions in this case were justified and lawful. At the same time, it should be noted that the judgment is a decision of first instance and may be appealed in accordance with the procedure prescribed by law.

In its judgment, the Court assessed whether the criteria relating to ownership and control in connection with a person included in the European Union (EU) sanctions list were met with regard to the applicant.

 

The Court’s judgment confirms FIU Latvia’s practice in the implementation of sanctions and contributes to the mitigation of risks related to sanctions circumvention.

 

The Court concluded that, in accordance with EU sanctions regulations and established practice, restrictive measures are applicable to the applicant. In the view of FIU Latvia, the applicant is indirectly owned by an undertaking controlled by a person included in the sanctions list; therefore, such an undertaking is considered to be an entity controlled by a designated person, whose funds and economic resources are subject to freezing. The Court found FIU Latvia’s conclusions to be well founded.

 

FIU Latvia recalls that the EU targeted financial sanctions regulation, as amended by the 19th sanctions package, includes definitions of the terms “owned” and “controlled”.1]

 

The definition of these terms strengthens legal certainty and promotes uniform practice across EU Member States by making them legally binding. It is important to emphasise that the definitions incorporated into the regulation are consistent with those explained in EU best practice; therefore, the fundamental principles for applying these terms in practice remain unchanged.

 

The FIU Latvia website provides access to sanctions lists and other useful information.

Since April 2024, FIU Latvia has been the national competent authority for sanctions implementation in Latvia.


[1] Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, Article 1(i) and (j).

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