Euro SIFMANet: Vilnius Report

Since its entry into force in May 2004 as part of Lithuania’s EU accession process, Lithuania’s sanctions legal framework has been based on the Law on the Implementation of Economic and Other International Sanctions. For years, sanctions were not perceived as a priority topic and were regarded as a foreign policy responsibility. This led the Ministry of Foreign Affairs (MFA) to assume the role of coordinator of international sanctions in the context of foreign policy dialogues.

In 2021, following the repression after the 2020 presidential elections in Belarus, the EU introduced a Council regulation to impose sanctions on Belarusian business entities and public authorities, as well as private individuals. This would set the course for a new approach in Lithuania. On the basis of its national law, Lithuania’s MFA was in charge of coordinating the implementation of these sanctions, which had previously not been a heavy imposition. However, given the intensity of Belarus sanctions implementation in light of the proximity of and business connections between Belarus and Lithuania, this became a much more onerous task. The difficulties faced by the MFA in ensuring effective implementation and the overall limitations offered by an outdated law demanded legislative changes.

After the Russian invasion of Ukraine in February 2022, Lithuania’s parliament redrafted the sanctions law with its revised version entering into force on 26 May 2022.

The findings in this report emerged from a roundtable discussion and a series of one-on-one meetings involving representatives from government ministries and agencies, and the private sector (such as banks, law firms and other organisations exposed to sanctions implementation) in Vilnius in late September 2022.