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Financial Intelligence Unit Obligated to Disclose International Sanctions

Tallinn, Estonia

The Financial Intelligence Unit (FIU) is required to promptly publish information about the imposition, amendment, or termination of international financial sanctions, according to a new law passed in Estonia.

Enhanced Transparency and Prevention of Misuse

• The FIU must make this information available on its website immediately after receiving it.
• This move aims to enhance transparency and prevent the misuse of funds by individuals or entities subject to these sanctions.

Suspension of Transactions and Limitations on Asset Disposal

• If the FIU has reason to believe that an individual or entity subject to international financial sanctions has used or disposed of funds or economic resources, it may:
  • Suspend a transaction
  • Impose a limitation on the disposal of assets for up to 30 working days
• The FIU will also notify relevant authorities and individuals with legitimate need-to-know about the measures taken.

Verification of Legality and Notification Procedures

• The law outlines procedures for verifying the legality of measures taken against individuals or entities subject to international financial sanctions.
• If the FIU confirms that an individual or entity is subject to these sanctions, it must:
  • Notify them in writing
  • Outline the scope and content of the measures taken
  • Provide the legal basis and procedure for contestation

Annual Survey of International Financial Sanctions Implementation

• The FIU will prepare and publish a consolidated survey of the implementation of international financial sanctions in Estonia at least once a year.
• The survey will include information on:
  • Identified subjects of financial sanctions
  • Measures taken
  • Exemptions made

State Supervision and Penalty Provisions

The law establishes procedures for state supervision over the implementation of international financial sanctions. The FIU will be responsible for conducting this supervision, unless otherwise provided by law or European Union legislation.

• Special measures of state supervision may be applied in certain circumstances.
• Failure to comply with these measures may result in penalty payments.
• The law also outlines penalties for non-compliance with other provisions, including:
  • Failure to notify the FIU of identification of subjects of international financial sanctions
  • Submission of false information
  • Failure to establish procedural rules

Entry into Force

The Act will enter into force four months after its publication in Riigi Teataja.