Lithuania: New sanctions in force since 1 September

The importance of this Resolution lies in the guidelines aimed specifically at the implementation of international sanctions. Chapter 3 (International sanctions risk management) of the Guidelines deserves special attention. Under the item No. 13, financial market participants (FMPs) are required to carry out an international sanctions risk assessment. This chapter further elaborates that an FMPs international sanctions risk assessment may be carried out either in conjunction with or separately from the money laundering and terrorist financing risk assessment of its overall activities. Item 15 sets out the groups of risk factors that must be assessed. Chapter 7 (Control of intermediary activities) of the Resolution sets out the mandatory steps applicable to financial market participants that are providing services in the Republic of Lithuania or in a foreign country through intermediaries.

 

Additionally, items 4-8 of  “Resolution No. 03-97, dated 30 May 2023 (“Resolution Amending Resolution No. 03-17 of the Board of the Bank of Lithuania of 12 February 2015 on the Approval of the Guidelines on the Prevention of Money Laundering and/or Terrorist Financing for Financial Market Participants”) came into force on the same day (1 September 2023). The above Resolution is important for the guidelines it provides on the implementation of anti-money laundering and terrorist financing measures. It should also be noted that item 2 of this Resolution, defining the specific targets of the guidelines, will come into force on 10 November 2023.

 

In order to avoid any future negative measures taken by the authority charged with supervising the obliged entities, all obliged entities are recommended to review their internal procedures and update them in accordance with the newly effective guidelines.