Sanctions-breach suspicion reports go to the FID, no longer the VDD

VID-supervised persons subject to the sanctions law — the same circle as the persons supervised under the anti-money laundering law, including external accountants, tax consultants, legal service providers, trust and company service providers, real-estate intermediaries, dealers in vehicles, precious metals, precious stones and other high-value goods where cash payments reach 10,000 euro, as well as providers of lending, guarantee, financial-consultancy and collection services — must file sanctions reports with the Finanšu izlūkošanas dienests (FID) as soon as suspicion of a violation or attempted violation of international or national sanctions arisesVID, using the procedure laid down in the Noziedzīgi iegūtu līdzekļu legalizācijas un terorisma un proliferācijas finansēšanas novēršanas likums.

The superseded instruction told these persons, upon establishing a sanctions-regime violation (konstatējot sankciju režīma pārkāpumu), to report to the State Security Service (ziņot Valsts drošības dienestam)VID. That instruction is goneVID: the recipient is now the FID and the trigger is mere suspicion, explicitly including an attempted violation. The report is filed in the procedure the anti-money laundering law prescribes — in practice through the goAML reporting system, by letter to the FID, or in person at the FID office.

Everything else around the duty is unchanged. A person handling assets of a listed person must still freeze that person's funds immediately and without prior warningVID, must not provide financial services to the listed personVID, and must not conclude civil transactions with themVID. The prohibition on acquiring goods or receiving services from persons subject to asset-freezing sanctions, and from persons owned or controlled by them, continues to apply.

Informing the competent institutions about possible sanctions violations is not treated as disclosure of confidential information, and a person that in good faith freezes funds or refuses to make them available bears no liability for doing so. Sanctions screening of existing and prospective clients remains mandatory regardless of the risk assessment, the transaction amount or the client's risk level; screening alone does not discharge the rest of the compliance duties.

The change aligns the guidance with the statute: the FID has been the competent institution for international and national sanctions enforcement and for combating circumvention of financial restrictions since 1 April 2024VID, it examines questions on statutory exceptions and authorisations, and it is the body that gives explanations in difficult cases, such as where information is insufficient for a reasoned decision or where it is uncertain whether an identified person matches a listed person. Legal basis: Starptautisko un Latvijas Republikas nacionālo sankciju likums, 13.1 and 17. pants, and the reporting procedure of the Noziedzīgi iegūtu līdzekļu legalizācijas un terorisma un proliferācijas finansēšanas novēršanas likums.