Strengthening Sanctions Against Russia in 2026: How Risks for Honest Cargo Owners and Carriers Are Changing and When Legal Counsel on Sanctions Is Necessary

This heightened focus helps to more effectively identify attempts to circumvent sanctions. At the same time, it leads to a noticeable increase in the burden on honest businesses: legitimate cargo may be delayed, and their owners and carriers often find themselves in situations where they are preemptively treated as potential violators during the initial inspection.

Circumventing Sanctions: How Violators Operate and What It Means

The sanctions regime of the European Union and Latvia stipulates that all participants in foreign economic activity, including exporters, importers, and logistics companies, must strictly adhere to established prohibitions and restrictions. An attempt to deliberately circumvent sanctions can itself become grounds for criminal prosecution. In 2024, more than 250 criminal cases related to the movement of sanctioned goods across the border were initiated in Latvia.

The most commonly involved items in such cases include:

• various types of electrical equipment;

• automotive parts and components;

• luxury goods;

• dual-use products (including chemicals, telecommunications, and aviation equipment).

In practice, common methods of circumventing sanctions include:

• distortion or forgery of commercial documents;

• incorrect classification of goods by customs code;

• indicating fictitious or formal countries of origin and final destination.

In conditions of intensified control, such schemes are increasingly being uncovered. The result for participants in such activities is usually the same: cargo detention, seizure of goods, initiation of criminal proceedings, and serious consequences for both companies and their executives.

Why Stricter Control Affects Law-Abiding Businesses

Intensified checks do not spare those entrepreneurs who operate their businesses in full compliance with the law. Even if declarations, contracts, invoices, and accompanying documents are correctly prepared, cargo may be delayed due to:

• suspicions that the goods actually fall under sanctions;

• doubts about the authenticity of the declared origin or final recipient;

• classification of specific goods or transportation routes as high-risk.

For businesses, this means:

• blocking of working capital during the inspection and storage of cargo;

• disruption of delivery deadlines and penalties under contracts;

• risk of spoilage of goods due to prolonged storage;

• potential reputational damage if the detention becomes known to partners or the public.

Sanctions lawyers at NJORD note a steady increase in requests from cargo owners and carriers who have faced delays of legitimate shipments due to sanctions-related suspicions. In many cases, with competent and timely support, it is possible to achieve the release of cargo and termination of proceedings, but this requires a well-thought-out legal strategy and an active stance from the business.

How to Reduce Sanction Risks in 2026

In a situation where sanctions control is becoming increasingly strict, cargo owners, exporters, importers, and carriers should reconsider their approach to risk management. Three blocks are particularly important: documentation, counterparties, and operational legal support.

1. Documentation: Completeness, Logic, Readiness for Inspection

Documents confirming the origin of goods, route, involvement of intermediaries, and data about the final recipient must be:

• complete and internally consistent;

• prepared in accordance with current EU sanctions regulations and Latvian legislation;

• systematically stored so that they can be quickly provided to regulatory authorities upon first request.

The more transparent and logical the documentation appears, the easier it is to justify the legality of the operation and the higher the chances of reducing the inspection time.

2. Verification of Counterparties and the Entire Supply Chain

Today, it is no longer sufficient to check only the direct partner in the transaction. It is necessary to systematically assess:

• the ownership structure and beneficiaries of the counterparty;

• possible connections with individuals and companies under sanctions;

• the likelihood that the goods will be re-exported to a prohibited jurisdiction.

In practice, this means implementing internal procedures for sanctions compliance within the company, regular monitoring of partners, and updating internal instructions as the sanctions regime changes.

3. Early Consultation with a Sanctions Lawyer

A specialized sanctions lawyer can help before concluding a deal by:

• assessing sanctions risks in advance and understanding whether the planned operation is permissible;

• correctly formulating the terms of the contract and distributing responsibilities among participants;

• preparing a package of documents that clearly demonstrates the legal nature of the transaction;

• acting promptly and within the legal framework in the event of cargo detention or the initiation of an inspection.

Criminal Liability for Violating Sanctions in Latvia

Sanctions are viewed not only as an element of foreign policy pressure but also as legally binding rules, the violation of which entails liability. In Latvia, non-compliance with sanctions imposed by the European Union, the United Nations, or Latvia itself is regulated, in particular, by Article 84 of the Criminal Code.

Depending on the severity of the violation, the following sanctions may apply:

• fines;

• community service;

• imprisonment.

Both individuals and executives and representatives of legal entities can be held liable. In certain cases, liability may also be imposed on the company itself if the violation occurred in connection with its activities. Moreover, attempts to circumvent sanctions through formally "gray" schemes are often assessed as strictly as direct disregard for prohibitions.

How a Sanctions Lawyer Can Help Businesses Under Strict Control

The team of sanctions lawyers at NJORD has practical experience in defending clients accused of violating the sanctions regime, as well as supporting law-abiding companies operating under intensified control.

We can:

• prepare and present evidence of the legality of operations, including expert opinions on the origin of goods, actual delivery routes, and absence of connections with sanctioned individuals and jurisdictions;

• seek the release of detained cargo and, when possible, termination of criminal or administrative proceedings or mitigation of their consequences;

• assist in reducing financial and reputational losses, including through careful communication with partners, regulatory authorities, and law enforcement agencies.

The strengthening of sanctions enforcement in 2026 makes the activities of those who deliberately violate the rules significantly more risky, while simultaneously increasing the burden on honest businesses. In this reality, thoughtful sanctions compliance and professional legal support play a key role.

Sanctions lawyers at NJORD are ready to support cargo owners, carriers, and other participants in foreign economic activity at all stages: from planning the transaction and building the supply chain to protecting interests during cargo detentions and handling criminal cases related to the sanctions regime.