The Financial Crime Investigation Service under The Ministry of the Interior of the Republic of Lithuania (FCIS / Finansiniu nusikaltimu tyrimo tarnyba prie Lietuvos Respublikos vidaus reikalu ministerijos – FNNT) has released its 2025 annual report on combating international sanctions violations. The findings reveal a sharp rise in enforcement actions, with total fines exceeding €6.2 million over the course of the year.
According to the official document, FCIS received 232 notifications from financial institutions regarding potential sanctions circumvention schemes. Following in-depth analysis of 77 reports, a number of cases were escalated to other competent Lithuanian and EU authorities for further investigation.
The most common violations leading to monetary penalties included:
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Export of sanctioned vehicles to Russia and Belarus;
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Unauthorized import and export of restricted goods to or from the European Union;
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Provision of logistics and warehousing services to sanctioned entities;
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Transfer of Euro banknotes to legal entities registered in Belarus.
Lithuanian Logistics Companies Increasingly Involved in Sanctions Evasion
The FCIS report highlights a significant and troubling trend: Lithuanian logistics companies are playing an increasingly active role in sanctions evasion networks. Authorities have identified systematic attempts to obscure the true nature of transactions through contractual loopholes.
Common tactics include:
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Shifting compliance responsibilities to the customer (e.g., a Belarusian firm);
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Falsely stating that goods are not subject to restrictions;
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Claiming that manufacturers meet sanctions requirements;
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Citing transitional periods in EU regulations to justify exports after legal deadlines.
However, according to FCIS, these justifications are often made without any real verification or tangible compliance measures. The absence of genuine due diligence leaves logistics providers exposed to heavy fines and reputational damage.
Enforcement Priorities and EU Sanctions Compliance
The 2025 data underscores Lithuania’s commitment to enforcing EU sanctions regimes against Russia and Belarus. With €6.2 million in penalties already issued, FCIS is sending a clear signal to businesses operating in cross-border trade, transport, and financial services: compliance is non-negotiable.
Companies engaged in logistics, warehousing, or export-import activities involving sanctioned jurisdictions are urged to conduct thorough risk assessments, implement robust internal controls, and ensure full transparency in contractual documentation.
The detailed FCIS report is available online
