Lithuania
1. Does Lithuania have a sanctions regime in place?
Yes.
2. Does Lithuania implement UN sanctions?
Yes. Lithuania implements international sanctions related to terrorism imposed by the UNSC (these are also implemented through EU legislation) as well as autonomous EU restrictive measures. These international sanctions are implemented according to the Law of Economic and other International Sanctions and other legal acts.
3. Does Lithuania implement an autonomous sanctions regime?
Lithuania has a list of individuals which are banned from entering the Republic of Lithuania, as well as a list of individuals sanctioned in relation to terrorism.
4. What is the nature of the sanctions regime in Lithuania?
Economic sanctions include: restrictions on the import, export, re-export and transit, including brokering, of goods for civil purposes, dual-use items, military equipment, services and technologies; restrictions on trade with entities with respect to which international sanctions are implemented; restrictions on the economic activities of natural and legal people of the Republic of Lithuania in a state or territory with respect to which international sanctions are implemented; and restrictions on economic activities in the territory of the Republic of Lithuania of the entities with respect to which international sanctions are implemented.
The institutions supervising the implementation of economic sanctions are:
- Ministry of Foreign Affairs
- Ministry of Economy and Innovation
- Customs Department under the Ministry of Finance
- Bank of Lithuania
Financial sanctions include: restrictions on the rights of entities, with respect to which international sanctions are implemented, to manage, use and dispose of cash, securities, goods, other assets and property rights; payment restrictions for entities with respect to which international sanctions are implemented; and other restrictions on financial activities.
The institutions supervising the implementation of financial sanctions are:
- Financial Crime Investigation Service under the Ministry of the Interior
- Customs Department under the Ministry of Finance
- Bank of Lithuania
Political sanctions include restrictions on official visits; restrictions on entry into, or transit through, a state or a territory with respect to which international sanctions are implemented; restrictions on entry into, or transit through, the territory of the Republic of Lithuania for the persons with respect to whom international sanctions are implemented; restrictions on diplomatic relations; and other measures of political and diplomatic influence. The institutions supervising the implementation of political sanctions are:
- Government and the ministries of the Republic of Lithuania
- Migration Department under the Ministry of the Interior
- State Border Guard Service under the Ministry of the Interior
Communication sanctions include: restrictions on transport (rail, road, water, air), postal and electronic communications; and/or other communication with entities with respect to which international sanctions are implemented. The institutions supervising the implementation of communication sanctions are:
- Ministry of Foreign Affairs
- Ministry of Transport and Communications
- Communications Regulatory Authority
- Civil Aviation Administration Public sanctions include: restrictions on cultural, scientific, educational, sports and other public relations with entities with respect to which international sanctions are implemented. The institutions supervising the implementation of public sanctions are:
- Ministry of Culture
- Ministry of Education, Science and Sports
- Department of Physical Education and Sports
The list of institutions supervising the implementation of all sanctions (economic, financial, political, communication, public) is non-exhaustive, and if it is necessary, Government may appoint other authorities responsible for supervising the implementation of such sanctions.
5. Does Lithuania maintain a list of sanctioned individuals and entities?
Lists approved by EU regulations are mandatory and applicable in Lithuania. The autonomous lists exist in relation to restriction on entry to Lithuania and terrorism related individuals.
6. Are there any other lists related to sanctions?
The Government of the Republic of Lithuania has approved two lists of countries in relation to a gun embargo in order to implement EU Council’s decisions. These lists indicate countries to which and from which it is restricted to export/import and transport via transit as well as intermediate regarding items that are included in the Common Military List.
7. Does Lithuania have a licensing or authorization system in place?
Yes. The Ministry of Foreign Affairs is entitled to apply exemptions (through permits) from the imposed sanctions. The entities with respect to which international sanctions are implemented, or natural or legal persons of the Republic of Lithuania seeking to avail themselves of the exemptions, must apply for permits to the institution charged with supervising the implementation of the relevant international sanctions (the names of those institutions are set out above). The supervising institution then applies to the Ministry of Foreign Affairs which considers exemptions on a case by case basis. Permits (for exemption) can only be granted with the consent of the Ministry of Foreign Affairs. Where the Ministry of Foreign Affairs is the institution carrying out supervision of the relevant international sanctions, permit applications can be made directly to the Ministry of Foreign Affairs of the Republic of Lithuania.
8. What are the consequences for a breach of sanctions in Lithuania?
Administrative liability: the breach of international sanctions executed in the Republic of Lithuania invokes a fine on individuals from EUR 200 to EUR 6000.
Criminal liability: a person who breaches international sanctions executed in the Republic of Lithuania, where this invokes a great harm for the interest of the Republic of Lithuania, shall be punished with either a fine (applies in respect of individuals or corporates), arrest or imprisonment for up to 5 years (arrest and imprisonment applies in respect of individuals). The maximum amount of fine for individuals is EUR 156,000 and for corporate entities is EUR 3.900,000.
Other consequences: it is prohibited to conclude transactions the execution of which would be in conflict with international sanctions implemented in the Republic of Lithuania. Such transactions concluded after implementation of international sanctions in the Republic of Lithuania in the manner prescribed by the Law on the Implementation of Economic and Other International Sanctions are null and void.
9. Who are the relevant regulators in Lithuania and what are their contact details?
Ministry of Foreign Affairs (Coordinating Authority) Transatlantic Cooperation and Security Policy Department J. Tumo-Vaižganto Str. 2 LT-01511 Vilnius Lithuania T: (+370) 5 236 2517 F: (+370) 5 236 25 19 E: urm@urm.lt
Bank of Lithuania
Financial and Economic Sanctions T: (+370) 5 268 0501, (+370) 5 268 0502 E: pt@lb.lt Other relevant authorities include:
- Government of the Republic of Lithuania
- Ministry of Economy
- Ministry of Transport and Communications
- Ministry of Culture
- Ministry of Education and Science
- Financial Crime Investigation Service
- State Border Guard Service
- Customs Department under the Ministry of Finance
- Migration Department under the Ministry of Interior
- Communications Regulatory Authority
Contributor law firm
Rimtis Puisys,
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Arnoldas Jokūbaitis, Senior Associate
Eversheds Saladžius
Victoria Tower
J. Jasinskio 16B
LT-01112 Vilnius
Lithuania
T: (+370) 5 239 2391
T: +370 5 239 2391 arnoldas.jokubaitis@eversheds.lt www.eversheds-sutherland.com
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