For our Risk management, corporate crime investigations, and defence team, 2025 was intense and full of complex cases. The year demonstrated how sensitive today’s business environment is to geopolitical tensions and how rapidly corporate risk is evolving under increasingly stringent regulation.
We handled a wide range of criminal, administrative, and regulatory offense cases, covering both “classic” corporate and executive liability as well as emerging risks related to international sanctions and financial matters.
The beginning of 2026 only confirms this trend – these developments are not only continuing but intensifying in many areas. We observe growing activity by law enforcement authorities alongside increasing expectations from businesses for clear, practical guidance that enables effective management of legal and reputational risks.
Key areas we worked on in 2025 and that remain relevant in 2026:
- Violations of international sanctions
- Financial and tax-related crimes
- Property crimes (fraud, misappropriation, embezzlement)
- Corruption-related crimes
- Violations of occupational safety and health requirements
- Traffic offenses
Our Team
Sorainen clients in these matters are advised by experts specializing in sanctions compliance, financial and tax disputes, and corruption-related criminal cases:
- Partner, Attorney-at-law Kęstutis Švirinas
- Expert, Attorney-at-law and Head of Sorainen’s Risk management, corporate crime investigations, and defence team in Lithuania, Darius Raulušaitis
- Attorney-at-law Dr. Ugnė Nasvytė
- Associate Žilvinas Rudys
We also represent victims and civil claimants (including companies) in criminal proceedings.
Violations of international sanctions
Sanctions compliance remained one of the most sensitive areas in 2025 and continues to be so. In practice, a key issue has emerged – the overlap between different types of liability:
- Administrative liability for individuals and company executives under the Code of Administrative Offenses
- Liability of legal entities under the Law on International Sanctions
- Criminal liability for both individuals and legal entities under the Criminal Code
Law enforcement authorities often face challenges in determining which type of proceedings to initiate, as clear criteria for distinguishing liability are still lacking.
We handled cases where individuals, including company executives, faced fines of tens of thousands of euros, as well as cases where companies risked substantial financial penalties under the Law on International Sanctions – up to 100% of the value of the goods, services, or funds involved.
In March 2025, our team’s attorney-at-law Dr. Ugnė Nasvytė presented at a joint conference organized by Sorainen and Vilnius University Faculty of Law on the intersection of criminal, administrative, and civil law, focusing on distinguishing administrative and criminal liability for sanctions violations. These insights became the basis for practical recommendations to clients exporting goods or technologies to higher-risk jurisdictions.
The first quarter of 2026 shows that sanctions enforcement will only become stricter. Businesses therefore need clear, tailored sanctions compliance and control policies.
Financial and Tax-Related Crimes
Financial crimes, including tax offenses and money laundering, continued to form a significant share of criminal cases in 2025, involving both company executives and legal entities.
It is noteworthy that Lithuanian law provides for both administrative and criminal liability for certain tax offenses (e.g., failure to pay taxes), depending on the amount involved.
Pre-trial investigations increasingly focus on:
- Proper fulfilment of tax obligations
- Accuracy of calculated taxes (VAT, corporate income tax)
- Risks related to undeclared wages
Expert opinions often become a key element in such cases – serving both as evidence and as a central point of dispute.
Accurate tax calculations, properly documented and compliant with applicable accounting standards, are critical. In practice, tax data often becomes decisive in defending the interests of parties involved in proceedings.
We provide legal assistance both in tax calculation matters and in disputes regarding their correctness.
We also represent clients – companies and individuals – when banks have frozen assets linked to alleged criminal activities, including money laundering or terrorist financing.
Property crimes: fraud, misappropriation, embezzlement
Cases involving property crimes are among the most common. These offenses involve unlawful acquisition of another person’s property, often through deception, false information, omission, or breach of trust.
Key challenges include:
- Distinguishing between criminal and civil liability
- Cases involving document forgery or fraudulent accounting
In one case, despite law enforcement refusing three times to initiate a pre-trial investigation, persistence and professional legal support led to the opening of an investigation into the misappropriation of nearly EUR 300,000 in company assets.
Bank fraud is also common – for example, using fake VAT invoices to obtain payments. In one case, due to swift legal action and coordination with authorities, more than EUR 500,000 was recovered for the client.
We provide both:
- Representation for victims and civil claimants
- Defence for suspects, accused persons, and convicted individuals
Our experience shows that timely collection of evidence and a clear legal strategy are crucial for effective representation on both sides.
Corruption-related crimes
Corruption-related offenses remain highly relevant. We represent both individuals and legal entities in such cases.
In 2025, corruption cases – including so-called “receipt” (expense reimbursement) cases – remained in the spotlight and gained momentum in court practice.
Following amendments to the Criminal Code, since October 2025 municipal council members have gained the possibility to seek exemption from criminal liability for all criminal acts. This topic was analysed by Dr. Ugnė Nasvytė in a legal knowledge portal article.
We increasingly observe cases involving expert consultations in public procurement processes. Allegations of bribery, trading in influence, or abuse of office are brought against:
- Company executives
- Individuals presenting products or equipment to potential buyers
- Public procurement experts
We also encounter private corruption cases, such as bribery of employees in companies providing public services.
To manage these risks, we work closely with public procurement law experts. Darius Raulušaitis, together with public procurement expert Dr. Edgaras Markevičius, presented at the VP PRO 2025 conference on permissible communication between contracting authorities and suppliers prior to procurement.
Violations of occupational safety and health requirements
Workplace accidents fall under criminal law when they result in serious injury or death.
Such cases often arise when employers fail to ensure:
- Compliance with safety requirements
- Proper equipment and vehicles
- Safe working conditions
There are also cases where employees misuse equipment and suffer injuries, such as falls from height or accidents involving hazardous machinery.
Key legal issues include:
- Whether the employee was properly trained
- Whether protective equipment was provided
- Whether the employer ensured effective safety management
Effective legal strategies have often allowed us to avoid lengthy criminal proceedings – reaching settlements with victims and terminating investigations with exemption from criminal liability.
Traffic offenses
We provide legal advice and representation in both administrative and criminal cases related to traffic violations – from the pre-trial stage to court proceedings – often achieving outcomes involving exemption from liability.