Can a Lithuanian company obtain an export license to ship dual-use software to a sanctioned end-user under EU rules?

Dear Sir/Madam,

I reviewed your query regarding the export of dual-use software from Lithuania to clients in sanctioned jurisdictions. As an export compliance consultant, I must warn you that this is a high-risk activity regulated strictly under EU Regulation 2021/821 and Lithuanian national law.

Here is the critical information you need:

1. Can you obtain a license for a sanctioned end-user?
Generally, no. If the specific end-user is a "designated entity" (subject to an asset freeze) on the EU Consolidated List of Sanctions, making economic resources (including software) available to them is prohibited, not just restricted. If the country is sanctioned but the client is not, a license is theoretically possible but requires rigorous scrutiny. The Ministry of the Economy and Innovation in Lithuania is the competent authority for issuing these licenses.​

2. Penalties for Non-Compliance
Operating without a license is a criminal offense. Under the Criminal Code of Lithuania, penalties for violating international sanctions or export controls can include severe fines and imprisonment for company directors. For example, Lithuanian authorities recently fined a company over €1.27 million for sanctions violations. Ignorance of the end-user’s status is not a valid defense.​

3. Proof of Due Diligence
To protect your company, you must implement an Internal Compliance Program (ICP). This involves:

Classification: formally determining if your software ECCN (Export Control Classification Number) matches Annex I of the EU Dual-Use Regulation.​

Screening: checking all parties against the EU, US, and UN sanctions lists.

End-User Certificate (EUC): obtaining a signed declaration from the client stating the software will not be used for military or prohibited purposes.​

Recommendation & Next Steps
Given the complexity of EU sanctions and the potential for criminal liability, I strongly advise against shipping any code until a full compliance check is complete.

I offer specialized, cost-effective consultations to help Lithuanian exporters set up their compliance frameworks and verify clients. We can discuss your specific software and target country in detail to ensure you are fully protected.

Please feel free to contact me on WhatsApp for a brief initial consultation

Best regards,