FCIS Issues Updated Guidelines for Lithuanian Entities on International Sanctions Compliance

The Financial Crimes Investigation Service (FCIS) has issued updated guidelines detailing obligations for Lithuanian entities regarding international sanctions compliance, specifically under the UNSCR 1373 framework.

Obliged entities must verify entities for Financial Sanction Checks against:

• EU international financial sanctions lists,
• UN Security Council resolutions on targeted sanctions, and
• FCIS manages the UNSCR 1373 list.

All assets — including funds, financial assets, property, and economic resources — belonging to persons or entities on the UNSCR 1373 list must be frozen immediately upon identification.

Reporting Requirements:

If funds or other financial assets are frozen under these sanctions, entities must notify FCIS within 2 working days.

The recommendation of ECOVIS ProventusLaw:

• Ensure current screening processes incorporate checks against the UNSCR 1373 list alongside existing EU and UN sanctions lists.
• Verify that systems are updated to conduct checks on targeted financial sanctions and the new UNSCR 1373 requirements.
• Implement internal controls to freeze any assets or resources linked to sanctioned individuals or groups per UNSCR 1373 guidelines.
• Designate staff and resources for immediate response to suspension orders, ensuring timely notifications to FCIS.
• Set up mechanisms for notifying FCIS within 2 working days of fund suspension actions.
• Document all communications and actions taken in compliance with the freezing requirements to support regulatory audits.
• Provide compliance and operations staff training on the new requirements for implementing UNSCR 1373 sanctions, covering obligations for checking, freezing, and reporting.
• Clarify Exceptions Handling to manage account maintenance and interest crediting appropriately for sanctioned accounts.

This update emphasises Lithuania’s commitment to strict adherence to international financial sanctions. Compliance teams should promptly integrate these new guidelines to mitigate risks of non-compliance.