EU SANCTIONS by The Center of Excellence in Anti-Money Laundering

General information about EU sanctions

• What do we refer to as EU sanctions?
• Why are sanctions imposed?
• Who can be sanctioned?
• Where and by whom are EU sanctions imposed?
• What type of sanctions can be imposed by the EU?
• What is the procedure for adopting and reviewing EU sanctions?
• What is a national competent authority in Lithuania? How to contact it?
• Where can I find information and updates on EU sanctions?

Implementation of EU sanctions in the Republic of Lithuania

• How are EU sanctions implemented in Lithuania?
• Who is responsible for implementing EU sanctions in the Republic of Lithuania?
• Are there any other sanctions related obligations that natural and legal persons engaged in economic activities within the EU, financial institutions and other entities or organisations established or operating in the country should comply with?

Monitoring of the implementation of EU sanctions in the Republic of Lithuania

• Who monitors the implementation of EU sanctions in the Republic of Lithuania?

Exceptions to the implementation of EU sanctions

• Can there be exceptions to the implementation of EU sanctions?
• Where should natural or legal persons in the Republic of Lithuania go to benefit from the exemption from the implementation of sanctions under the EU Regulation?
• How long can it take to decide on an exemption?

Practical issues and recommendations

• What steps are recommended to avoid the risk of breaching EU sanctions?
• Why is it important to know your business partner?
• Can a transaction concluded before the implementation of EU sanctions in the Republic of Lithuania be carried out?
• Is a transaction concluded after the decision to implement EU sanctions in the Republic of Lithuania valid?
• Do EU sanctions also apply to banking transactions?
• Can a contract with an entity subject to EU sanctions be terminated?
• The company has business relations with Belarus. Will this aect its payments?
• Does a financial institution have the right to interrupt any payment from Belarus?
• The company makes periodic payments to the same business partner in Belarus. Why does the financial institution ask for additional supporting documents each time a payment is made?
• Can legal advice be sought from a financial institution before making a payment to Belarus?
• How can one verify that there is an exact match between an entity on the sanctions list and a business partner/customer?

The most common definitions in the context of EU sanctions

Useful references

• List of legal acts regulating the implementation of international sanctions in the Republic of Lithuania
• General guidelines for the implementation of EU restrictive measures
• Recommendations and guidelines from the European Commission
• Regarding the implementation of EU restrictive measures applied to Iran
• Regarding EU restrictive measures applied in respect of Belarus
• Regarding EU restrictive measures in response to the crisis in Ukraine