Operations in the customs area may be restricted, and the right to transport goods may be denied

2025. June 10, [year], amendments to the Criminal Law came into force, stipulating that criminal liability for violations of international and national sanctions arises only if the value of sanctioned goods or services reaches 10,000 euro. However, if the value of sanctioned goods is less than 10,000 euro, administrative liability applies to the person:

1. for natural persons – a fine up to 10,000 euro;
2. for legal entities – a fine up to 30,000 euro.

These amendments led to a broad review of previously initiated criminal proceedings – in several cases, criminal proceedings were terminated, and cases were transferred within the framework of administrative offense proceedings. This article does not assess the justification of such an approach. What is important is that a significant number of decisions have now been adopted by customs authorities regarding the administrative liability of declarants, carriers, freight forwarders, importers, and exporters for violations of European Union sanctions. Some of the penalized persons are merchants registered abroad, which significantly complicates the recovery of the imposed fines.

However, the problem of recovering administrative penalties did not arise only in 2025. It has existed for a long time. For example, between 2022 and 2024, administrative penalties totaling 591,745.85 euro were imposed for customs violations, of which only 329,053.24 euro, or slightly more than 55.6%, were paid. It is predicted that with the increase in the number of administrative offense cases in 2025, the number and amount of unpaid penalties will also increase. At the same time, an effective mechanism for the recovery of these penalties still does not exist. It is precisely to address this problem that amendments to the Customs Law have been adopted.

Restrictions on Customs Operations

To address the problems of recovering administrative penalties, including those concerning foreign declarants, exporters, importers, customs procedure users, and carriers who evade payment of imposed fines, restrictions on customs operations are planned.

More precisely – amendments to the Customs Law stipulate that from July 2026, a person who has not paid an administrative fine within the statutory period for:

1. a customs violation (for example, a violation provided for in Article 29 of the Customs Law – submitting false information or documents to the customs authority); or
2. a violation in the field of international or national sanctions of the Republic of Latvia,

will be prohibited from performing customs operations for which an EORI number is required, until the fine is paid.

An EORI number is a unique identifier used throughout the European Union to identify persons in the customs area. In Latvia, an EORI number is assigned in accordance with Cabinet Regulations and is necessary for performing certain customs operations.

When performing risk management for persons who have not paid an administrative fine for a customs violation or a sanctions violation within the statutory period, an entry regarding the unpaid fine will be made in the Electronic Customs Data System (EMDAS) for the respective person.

If such a person later wishes to perform customs operations requiring an EORI number, EMDAS will automatically generate an informative notification for the customs official regarding the applicable prohibition. Accordingly, the customs official will refuse to make a decision on the person’s declared operations, and EMDAS will also prevent the automatic adoption of a favorable decision.

Additional Restrictions for Carriers

Similar restrictions will also apply to carriers. If a carrier has not paid an administrative fine within the specified period, goods will not be released under customs procedures if their transport is carried out by the respective carrier.

The law stipulates that until the fine is paid, the carrier will be prohibited from transporting goods subject to customs clearance within the territory of the Republic of Latvia.

This May Also Affect Business Partners

Given the planned regulation, its impact may affect not only the penalized person but also their business partners. For example, if a carrier or customs representative has an unpaid administrative fine, it may also affect the client’s ability to complete customs procedures in a timely manner.

Therefore, it will be particularly important for companies organizing goods transport through Latvian territory to carefully evaluate their cooperation partners.

Information Will Be Disclosed to Business Partners

In addition to the measures mentioned above, the law provides for granting the State Revenue Service new rights aimed at preventing the circumvention of international and national sanctions. Namely, the SRS will be entitled to inform persons indicated in a customs declaration, re-export declaration, or re-export notification about other persons indicated in the same declaration or notification who have violated sanctions imposed by international organizations or the Republic of Latvia in connection with the import of goods into the European Union (import) or export from the European Union (export).

It is important that the SRS will be entitled to disclose such information without the consent of the person about whom the information is provided.

The purpose of such regulation is to ensure that persons involved in a transaction can timely assess cooperation risks and avoid involvement in transactions related to the import or export of sanctioned goods.

In practice, this can significantly affect the reputation of carriers, customs representatives, brokers, freight forwarders, declarants, and other persons involved in the customs area, as information about sanctions violations may be disclosed to their business partners. Consequently, companies will have to particularly carefully evaluate involvement in transactions where there is a risk of sanctions violations.

Although the law has not yet been promulgated, it is expected to be promulgated and enter into force in July 2026.

If your company faces decisions made by customs authorities or requires their appeal, we provide legal assistance in customs and sanctions law matters, including representing clients in administrative proceedings and litigation.