On 10 June 2025 Latvia completed the transposition of Directive (EU) 2024/1226 by amending three key statutes: the Criminal Law, the Law “On the Procedures for the Coming into Force and Application of the Criminal Law,” and the Law on International and National Sanctions of the Republic of Latvia.
Redefining the Offence
The existing offence “Violation of Sanctions Imposed by International Organisations and the Republic of Latvia” (Article 84 of the Criminal Law) has been comprehensively redrafted. The vague notion of a “breach of sanctions” is now spelled out as: purchasing, selling, moving sanctioned goods across Latvia’s state border, providing intermediary, technical or other related services, or performing any other prohibited activity with these goods, when done in a significant amount.
A “significant amount” is expressly quantified as €10 000 or more (Art. 23¹(4) on the Procedures for the Coming into Force and Application of the Criminal Law). Transactions below this threshold trigger administrative, not criminal, liability.
For strategic goods, firearms, essential firearm parts, ammunition, or military-purpose goods/technology, criminal liability applies regardless of amount.
Escalating Penalties
Latvia now distinguishes between administrative and criminal consequences purely on the monetary value of the sanctioned transaction:
- Transactions worth under €10 000 (handled as an administrative offence).
- Individuals risk a monetary penalty of up to 2 000 fine-units (presently €10 000).
- Legal entities may be fined up to 6 000 fine-units (presently €30 000);
- Transaction over €10 000 (handled as an criminal offence):
- imprisonment for up to five years, or to short-term deprivation of liberty, or to probation supervision, or to community service, or to a monetary fine.
- if the act is committed by a group of persons acting in prior concert, or by a public official, or by a responsible employee of a company (commercial enterprise) or other organisation – to imprisonment for up to ten years;
- if the offence is committed on a large scale or by an organised group – to imprisonment for up to twelve years;
- In case of strategic goods, firearms, essential components of firearms, firearm ammunition or goods or technology intended for military purposes:
- to imprisonment for up to eight years;
- if the act is committed by a group of persons acting in prior concert, or by a public official, or by a responsible employee of a company (commercial enterprise) or other organisation – to imprisonment for up to ten years;
- if the offence is committed on a large scale or by an organised group – to imprisonment for up to twelve years.
Enforcement Statistics
Between 5 May 2022 and 29 February 2024 the State Revenue Service’s Tax and Customs Police (SRS NMPP) opened or received 310 criminal proceedings related to Article 84—26 % of all investigations on its books. Incoming materials on sanctions breaches accounted for 40 % of the unit’s total caseload.[1]
Conclusion
Through precise statutory definitions, explicit monetary thresholds, and more severe penalties, the national framework now mirrors EU standards and delivers a strong deterrent effect. Businesses operating in or via Latvia must therefore promptly overhaul their screening, classification, and documentation procedures.
By Armands Rasa, Partner, and Anete Boze, Attorney, Widen
