Global sanctions guide

  1. Does Lithuania have a sanctions regime in place?


  1. Does Lithuania implement UN sanctions?

Yes. Lithuania is a member of the European Union, which implements UN sanctions in all member states by way of directly applicable regulations.

  1. Does Lithuania implement an autonomous sanctions regime?


  1. What is the nature of the sanctions regime in Lithuania?

Lithuania follows the restrictive measures laid down by the UN, the EU and other international organisations which are binding on Lithuania. Lithuania’s main legislation for implementing international sanctions is the Law on the Implementation of Economic and Other International Sanctions 2004.

Economic sanctions include: import and export controls, trade restrictions, arms embargoes and restrictions on economic activities of natural and legal persons (both Lithuanian persons and entities outside of Lithuania, and all persons and entities in Lithuania). Lithuania’s economic sanctions regime is supervised by the Ministry of Foreign Affairs, Ministry of Economy, Customs Department (part of the Ministry of Finance) and the Central Bank of Lithuania.

Financial sanctions include: restrictions on the use and movement of financial assets, payment restrictions for sanctioned entities, and other restrictions on financial activities. The financial sanctions regime is supervised by the Financial Crime Investigation Service (part of the Ministry of the Interior), the Customs Department, and the Central Bank of Lithuania.

Political sanctions include: restrictions on official visits, travel restrictions, restrictions on diplomatic relations, and other measures of political and diplomatic influence. The political sanctions regime is supervised by the government of Lithuania and its ministries, the Migration Department (part of the Ministry of the Interior), the State Border Guard Service (also part of the Ministry of the Interior), and the Department of Tourism (part of the Ministry of Economy).

  1. Does Lithuania maintain a list of sanctioned individuals and entities?

No. Lithuania relies on UN and EU sanctions lists.

  1. Are there any other lists related to sanctions?


  1. Does Lithuania have a licensing or authorisation system in place?

Yes. The Ministry of Foreign Affairs can issue permits which exempt persons or entities from economic sanctions. The applicant must apply to the institution responsible for supervising the relevant sanction (as set out at Question 4), which in turn applies to the Ministry of Foreign Affairs. Where the Ministry of Foreign Affairs is responsible for supervising the relevant sanction, applications can be made directly to the Ministry for an exemption permit. Applications are considered on a case-by-case basis.

  1. What are the consequences for a breach of sanctions in Lithuania?

The consequences of a breach of sanctions are:

  • administrative liability: persons can be fined from €144 to €14,481
  • criminal liability: persons can be fined and/or imprisoned up to 5 years.  The maximum fine for individuals is €38,000 and for corporate entities is €1,900,000
  • other consequences: any transactions concluded in breach of existing sanctions are null and void
  1. Who are the relevant regulators in Lithuania and what are their contact details?

The Ministry of Foreign Affairs is the coordinating authority for sanctions in Lithuania.

Ministry of Foreign Affairs
Transatlantic Cooperation and Security Policy Department
J. Tumo-Vaižganto Str. 2
LT-01511 Vilnius

T: (+370) 5 236 2517
F: (+370) 5 236 25 19

The Central Bank of Lithuania is responsible for financial and economic sanctions.

Central Bank of Lithuania
Supervision Service
Zirmunu Street 151

T: (+370) 5 268 0501, (+370) 5 268 0502
F: (+370) 5 261 5665

Other relevant authorities include:  the Ministry of Economy, the Financial Crime Investigation Service, the State Border Guard Service, Customs Department, Migration Department, and Communications Regulatory Authority.

Contributor law firm

Rimtis Puisys, Eversheds Saladžius, Victoria Tower, J. Jasinskio 16B, LT-01112 Vilnius, Lithuania