Amidst continued uncertainty regarding Russia’s ongoing war in Ukraine, Latvia and other Baltic states are considering ending their support for the Ottawa Landmine Treaty in the name of national defence. While the decision underscores Latvia’s current fears of vulnerability to Russian aggression, it also poses complex implications for NATO operational cooperation and Canada’s humanitarian commitments. This policy memo examines the implications of the Baltic states’ possible withdrawal from the Treaty on Canada’s leadership and joint NATO operations in Latvia. It offers recommendations on how Canada can retain its international legal obligations while continuing to work successfully with Latvia and the rest of NATO through joint military operations.

Russia’s Threat

Russia’s persistent aggression towards Ukraine has led many of its neighbours to reassess their national security strategies. Poland and the Baltic states have expressed rising concerns, claiming that the regional security environment has ““. Although Russia remains primarily focused on Ukraine, Western intelligence agencies have warned of its long-term plans to challenge NATO’s Eastern flank. In the next three to four years, it is theorized that Russia plans to rebuild and strengthen its military forces, leading to the large potential of an escalated attack . Due to Latvia’s proximity to Russia and location on NATO’s Eastern flank, anticipation of a future attack and motivation to test NATO’s defence readiness are . The Latvian defence intelligence community recently presented heightened warnings of Russia’s military developments and threats, such as infiltrating Latvia’s rural areas.

Treaty Details

was adopted in 1972 to ban the current and future possession, production, and transfer of anti-personnel landmines. The international agreement is currently , excluding Russia and the United States.

Latvia, Poland, Lithuania, and Estonia from the Ottawa Treaty Agreement in late March 2025, amidst rising national security concerns regarding Russian aggression. On April 16th, Latvia’s parliament (the Saeima) voted to officially withdraw from the agreement. With this vote, Latvia became to formally apply to leave the Ottawa Treaty. members of parliament voted in favour of the withdrawal, leaving fourteen against and two abstentions. Latvia set the stage for Lithuania’s parliament (the Seimas) to follow, to leave the treaty just a few weeks later on . Riigikogu, Estonia’s parliament, on June 4th, with 81 members in favour, out of 101 members. The Baltic states must inform all other treaty parties, as well as the United Nations Security Council and Secretary General, of their intentions to withdraw. The state must then wait a before the treaty ceases to apply. This period now gives the Baltic states an opportunity to address concerns with other NATO states on their plans for navigating the future of their defence against Russia.

Despite all three countries being politically aligned to support the decision, they have nonetheless faced backlash from global humanitarian organizations and humanitarian diplomatic figures. Examples include the large banner placed on Geneva’s iconic broken chair statue by the as a direct message to the Baltic states, Finland, and Poland, advocating against withdrawal discussions. Opposition has been expressed from various humanitarian organizations, including a statement by a top human rights official, Volker Türk, from the and , denouncing the decision. A key Canadian leader in diplomatic efforts to establish the Ottawa Treaty, that this move will risk long-term humanitarian consequences in the region.

Apart from a global humanitarian response, gauging local civilian perspectives on the withdrawal remains difficult. Literature or data regarding citizen opinion on the issue across all three Baltic states is scarce, making it a challenge to assess domestic support or opposition

Implications for Canada and NATO

Despite Canada’s continued commitment to the Ottawa Treaty, the potential exit of Latvia, Lithuania, and Estonia raises questions about the future of Canada’s operational relationship with each of these Baltic states. This question arises because the Ottawa Treaty extends beyond the possession, production and transfer of anti-personnel landmines to also of any state using landmines. The Canada-Latvia relationship is especially sensitive to this change, as Lativa currently hosts approximately 1,600 members of the Canadian Armed Forces deployed under . This operation has been extended by Mark Carney for three more years.

Canada also leads a NATO brigade in Latvia made up of troops from 13 Allies. Last year, this brigade successfully conducted , which was the first major field exercise . As activity in this region grows, it is necessary to continue assessing the alignment of the Baltic states with Canada’s treaty obligations and commitments to NATO cooperation as a whole. Canadian leadership plans to expand its brigade by adding 2,200 Canadian Armed Forces (CAF) members apart of the operation .

NATO as an organization prioritizes a collective defence strategy; however, states still hold a level of sovereignty to make military-related decisions. The decision by Latvia, Lithuania, and Estonia to leave the Ottawa Treaty suggests that humanitarian concerns are being sidelined in favour of state survival. Whether this shift has an effect on the level of cooperation between Canada and the Baltic states remains to be seen. In order to mitigate this potential change, this policy memo provides two recommendations for Canadian government officials to consider as they assess their relationship with their Baltic Allies.

Recommendation: Canada-Latvia Bilateral Dialogue on Operational Framework

An initial bilateral meeting between Canada and Latvia should take place focusing on creating a plan for navigating new legal circumstances as they emerge in the international security arena. Although Prime Minister Mark Carney did in late August to discuss the extension of military operations in the region, there was no public indication that the topic of landmines was discussed. It is necessary for Canada to engage with Latvian counterparts at the level of defence ministers and senior military leadership. By involving both political authority and operational expertise, both states can ensure that diplomatic commitments are aligned with on-the-ground coordination of operative measures. Assessments should be made to weigh the need for additional legal documents such as non-involvement clauses to ensure that Canada would not engage in activity that would undermine the Treaty.

During initial meetings, Canadian and Latvian officials should seek to establish an understanding of the effects that Latvia’s withdrawal may have on joint operations. A discussion around Canada’s legal obligations should be at the forefront of the discussion. Future NATO exercises and training should be reviewed, and new scenarios should be drawn, should Latvia indicate an intention to incorporate anti-personnel landmines into joint training activities.

To institutionalize this collaboration, both states should consider establishing a Canada-Latvia Operational Working Group. This group would create a permanent, ongoing cooperation between both parties, which would address legal and logistical updates as needed.

While the priority lies in communication with Latvia due to operational duties, Canada should consider exploring avenues for broader engagement with Lithuania and Estonia to strengthen diplomatic relationships in light of changing political and legal conditions.

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Russia’s war in Ukraine has fueled political radicalization in Latvia with far-reaching implications for national security. This policy brief examines how radical attitudes and behaviours have evolved in Latvia’s society – particularly online – under the influence of Russian propaganda, disinformation, and cyber operations since Russia’s full-scale invasion of Ukraine began in February 2022.

 Latvia, in response to Russia’s aggression and anxiety regarding its shared border, has embarked on a set of to secure national security and decouple from the Soviet past. These consisted of extensive , humanitarian, and to Ukraine, securing the national information space and shaping historical memory. The Latvian government has taken steps to prohibit and related online sites. and symbols have been removed from public places. While these efforts were done in the name of preserving Latvian sovereignty, they also , many of whom perceived this as an attempt to rewrite history.

Thus, Latvia faces a risk of radicalization among specific segments of its population as a direct and indirect consequence of Russia’s hybrid warfare. Hybrid threats have been systematically used to deepen societal cleavages and foment extremist sentiments. The Russian-speaking community (making up slightly more than one-third of Latvia’s population) is a target of Kremlin propaganda, wherein Latvia is framed as “Russophobic”, thus allowing Russia to spread its narratives among these populations.

This trend threatens Latvia’s internal security and has an added strategic security dimension as a polarized and unstable Latvia, a key NATO member, would benefit Russia and its efforts to undermine the solidarity of the NATO Alliance.

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Amid the ongoing war in Ukraine, Latvia is increasingly confronting the issue of companies using third countries to evade international sanctions. Many companies, particularly in the information and communication technology (ICT) sector, use transit jurisdictions, undermining international efforts and national security. Traditional sanctions alone are insufficient, as . This memo explores the potential of corporate self-regulation through corporate social responsibility (CSR) as a proactive alternative.  

CSR allows companies to voluntarily exclude themselves from unethical practices, ensuring that each employee takes responsibility for compliance with established norms. Participation in such ethical business practices could enhance . This issue is particularly pressing as the to finance Russia’s war against Ukraine, making it a matter of national security. While the circumvention of sanctions occurs across various industries, this paper focuses on the self-regulation mechanisms implemented by Latvian ICT companies. An assessment of Latvia’s five largest ICT companies shows considerable variation in their compliance with self-regulatory standards. Only a few meet most criteria, likely because prior reputational issues have prompted greater efforts. Key gaps include: weak public advocacy, limited third-party transparency, and insufficient training on sanctions compliance.   

This memo concludes that self-regulation practices concerning sanctions compliance among Latvian ICT companies are insufficient, especially in light of the war in Ukraine. Recommendations include encouraging CSR-based compliance frameworks, improving transparency, and considering a legal model similar to the United Kingdom (UK) Bribery Act 2010 to promote ethical business conduct and accountability. As sanctions circumvention directly impacts Latvia’s economic security and geopolitical independence from Russia and Belarus, promoting stronger self-regulatory and legal mechanisms are essential. This approach could also be applied to other high-risk sectors such as construction and extractive industries.

The Problem

The issue of sanctions circumvention, particularly through third countries, has become acute since Russia’s full-scale invasion of Ukraine in 2022. indicates that many Latvian companies use states in Caucasus and Central Asia as intermediaries to get around international sanctions. For example, in 2024 the Deputy Director of the Customs Administration – without disclosing the names of specific companies – noted a sharp increase in the number of sanctions violations committed by Lativan companies. The export of goods was prohibited in more than related specifically to Central Asian countries. This report highlighted that the goods being intercepted are mostly various mechanical devices, vehicles, and electrical equipment. Similar increases have been observed in Germany, as reported in a by Robin Brooks. There is about the need for against companies that facilitate such activities. However, it is evident that this approach is not , as it often fails to address the , namely, that the same individuals can establish new legal entities, continue their operations under a different owner, or employ alternative schemes to .  

The Context

In the case of CSR, compliance with economic sanctions is not a well-documented subject. According to relevant literature on the topic, sanctions compliance could be indirectly linked with topics, such as ; corruption risks associated with ; as well as s. CSR is also generally accompanied by an that aids in internalizing and implementing its provisions, as well as adhering to its own established standards and norms. Furthermore, the literature emphasizes the necessity of a proactive and innovative approach in developing supplementary mechanisms that beyond mere regulatory compliance. 

There are related but not directly addressed topics about sanctions compliance within CSR. In 2025, the United Nations Working Group on Business and Human Rights released a implying that businesses should comply with all relevant legal frameworks, which could include sanctions. Maayan Menashe that international standards can become embedded as social norms within corporations, influencing their behaviour even when legal enforcement is weak or absent. Similarly, sanctions compliance can be reinforced by market and societal expectations, making circumvention more reputationally and financially costly. According to Hortense Jongen, the private sector is facing pressure to , particularly in areas like anti-bribery and corporate responsibility, because of scrutiny from . Just as firms voluntarily align their CSR policies with international standards to maintain credibility, according to Bryan R. Early and Timothy M. Peterson, they may also adopt stricter compliance policies regarding sanctions to avoid being . A strong example of corporate response to geopolitical events is the reaction to Russia’s invasion of Ukraine, with over 1,000 companies publicly announcing the beyond the minimum legal requirements imposed by international sanctions. 

 A recent study by Keith A. Preble and Bryan R. Early claims that a critical aspect of compliance with economic sanctions is , with enforcement agencies leveraging “naming and shaming” tactics to deter violations. Firms fearing reputational damage are less likely to engage in risky transactions with sanctioned entities, and the heightened scrutiny on large corporations creates industry-wide compliance pressures. However, the authors also , with American institutions imposing significantly higher fines on foreign entities to ensure global compliance. Similar conclusions come from a study which , particularly those imposed on Russia after its 2022 invasion of Ukraine, through a survey of 610 medium-sized companies in Germany, Poland, and the United States (US). This analysis finds that, while external pressure generally encourages compliance and even overcompliance, it can also push some firms toward sanctions circumvention. Compliance is often accompanied by proactive business strategies aimed at finding legal loopholes to continue operations. The results of this study underscore the – US firms, for instance, face stronger legal enforcement mechanisms, whereas firms located in the European Union (EU) , particularly in Germany and Poland, exhibit a wider spectrum of compliance behaviors. These findings suggest the need for stronger enforcement mechanisms, standardized regulatory guidance, and targeted measures to curb both undercompliance and sanctions circumvention. 

To gain insight into how such regulatory measures are implemented by Latvian ICT companies and what the most popular approaches are, this memo examines the largest ICT enterprise, including a review of corporate statutes, annual reports, as well as open and publicly available data. The evaluation is conducted based on criteria aligned with  international standards. However, the criteria used in this memo are modified to reflect the existing narrative on sanctions circumvention, specifically addressing political involvement, corruption risks associated with third-party involvement, and public anti-corruption stance. The assessment is conducted based on a scoring system, where “Yes” is assigned 1 point, “Partially” is assigned 0.5 points, and “No” is assigned 0 points, depending on the extent to which the information found in the company’s documentation aligns with the methodological criteria.  

The methodology to review the most popular approaches is based on ISO 37001 (), ISO 26001 standards (), (training programs), (third-party involvement and whistle-blowing) and (sanctions compliance and restricted parties). State-owned companies or companies that have previously been state-owned are excluded from the study. Primarily, publicly available information about companies is included, and letters requesting answers to specific questions were sent out to relevant companies as a secondary source.  

Table No.1 Criteria to review most popular self-regulatory approaches 

Table No.2 Evaluation of the largest Latvian ICT companies 

Overall, self-regulatory approaches and their implementation among the five largest Latvian ICT companies can be characterized as insufficient according to the utilized methodologies. There are significant disparities in the extent to which companies comply with the requirements, with some demonstrating full or near-full compliance, while others fail to comply with any of them.  

The lowest performance was observed in areas such as advocacy for sanctions compliance, transparency regarding meetings with public authorities, and disclosure of industry association memberships. In addition, most companies disclose only their own offices and a limited number of partners, failing to provide comprehensive disclosure of partners across different jurisdictions. Furthermore, there is insufficient recognition of anti-corruption and anti-bribery compliance programmes, and whistleblowing mechanisms for employees are largely absent. Additionally, based on the analysis of social media and website content, as well as information obtained through formal correspondence, existing training programmes appear to inadequately cover all key topics. Typically, employees across all levels receive uniform training content on anti-corruption and compliance, with no specific reference to sanctions compliance. 

Conclusion and Recommendations

Given the inconsistent approaches among businesses in implementing sanctions compliance policies, it may be beneficial to consider a legal framework similar to the . This legislation has motivated both domestic and foreign companies operating in the UK to establish , as failure to do so may result in legal liability. A comparable framework could be developed for sanctions compliance in Latvia – clearly defining what constitutes a sanctions violation and establishing enforcement mechanisms. Such a framework should also include provisions for holding companies accountable for failing to prevent sanctions circumvention or violations. 

At the same time, such measures may be considered controversial, as critics might claim that these regulations internationally, potentially undermining short-term competitiveness. Criticism of this regulatory framework often comes from and various private sector actors – particularly those where law enforcement institutions are less advanced. In such contexts, companies based in developed economies can exploit institutional weaknesses to serve their own interests. This issue underscores the broader phenomenon whereby business actors from developed countries ‘export corruption’ and take advantage of their cooperation partners in developing countries. To mitigate such practices, only a few jurisdictions have introduced specific regulations, for instance, foreign bribery committed by U.S. nationals or persons located in the country is addressed under the . 

Analysis of ICT companies in Latvia reveals differing approaches to sanctions compliance. It is important to acknowledge that , , long term, often involving tax avoidance, tax evasion, tax fraud, and money laundering. Given Latvia’s current , there is a strong case that implementing such a regulatory framework could positively influence corporate decision-making, especially in selecting international partners. The evaluation shows that only Tietoevry Latvia has largely met most criteria, likely as a result of efforts to involving Belarus. In other cases, the extent of compliance remains incomplete.  

In sum, based on the analysis conducted, the following recommendations are proposed for Latvian policymakers and other relevant stakeholders: 

1. Develop a comprehensive legal framework for sanctions compliance. It is recommended that policymakers establish a legal framework for sanctions compliance and prevention of foreign bribery, modelled on the UK’s Bribery Act 2010; 

2. Promote enhanced corporate due diligence in partner selection. Companies should be encouraged to strengthen their due diligence practices, particularly when selecting international business partners, especially in high-risk geopolitical contexts; 

3. Expand compliance evaluation to other high-risk sectors. It is advisable to apply the compliance evaluation methodology currently used in the ICT sector to other high-risk industries, including construction and extractive sectors. 

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