Publications
“High standards of professional work.” (IFLR1000, 2017)
In the February 2020 issue of iTiesības, an article by Kristīna Markeviča, associate of PRIMUS (Certified Anti-Money Laundering Specialist (CAMS)), dealing with major aspects when complying with and executing international and national sanctions, was published.
Should each client be checked against sanctions lists?
According to the Ministry of Foreign Affairs (MFA), sanctions are restrictive measures, or restrictions or prohibitions, imposed pursuant to international public law. Any transaction prohibited under the law governing sanctions is considered a breach of sanctions.
Failure to comply with sanctions, as well as suspicion of a breach of sanctions, may carry the risk of the suspension of economic activities and the freezing of funds for the defaulting economic operator, because the State Police has the right to seize all funds of such economic operator in order to prevent a breach of sanctions, and this is what actually happens in practice.
Therefore, in order to minimise the likelihood of being involved in circumvention of the sanction regime, those which, on account of their activities, are not required by law to establish an internal sanction control system (in the case described in this article, online shops) should at least follow the following four steps when assessing their counterparty:
The full article in latvian is available in the February 2020 issue of iTiesības.