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Estonia Enforces UN and EU Sanctions with Strict Regime

Estonia has a strict sanctions regime in place to enforce international sanctions imposed by the United Nations (UN) and the European Union (EU). Unlike some other countries, Estonia does not have an autonomous sanctions regime of its own; instead, it follows the restrictive measures laid down by these organizations.

Main Legislation for Enforcing International Sanctions

The main legislation for enforcing international sanctions in Estonia is the International Sanctions Act 2019. In cases where international sanctions do not directly apply, the government passes laws to implement them. For example, an arms embargo is enforced through the Strategic Goods Act 2011.

Individuals and legal entities are required to notify the Estonian Financial Intelligence Unit if they know or suspect that someone with whom they are doing business is subject to international financial sanctions. Certain entities, such as banks, have more onerous obligations to uphold sanctions.

Sanctions Lists and Exemptions

Estonia does not maintain its own list of sanctioned individuals and entities; instead, it relies on UN and EU sanctions lists. The country also has no other lists related to sanctions. A licensing or authorization system is in place for exemptions from trade and financial sanctions. Prior authorization may be obtained from the relevant ministry or the Financial Intelligence Unit for exemptions.

Consequences of Breach

Breach of sanctions can result in severe consequences, including fines or imprisonment for up to five years. In some cases, transactions that breach the International Sanctions Act may be voided unless an exemption is available and retrospective authorization is granted.

Implementation and Administration

Estonian authorities have implemented international sanctions through various administrative agencies. The Ministry of Foreign Affairs proposes sanctions to the government, while other ministries are responsible for specific aspects of sanctions enforcement, such as restrictions on stay, residence, and employment.

For more information or advice on Estonia’s sanctions regime, please contact:

  • Ministry of Foreign Affairs: Islandi väljak 1, Tallinn 15049; (+372) 6 377 000; www.vm.ee/en/
  • Police and Border Guard Board: Pärnu mnt 139, Tallinn 15060
  • Ministry of Economic Affairs and Communication: Suur-Ameerika 1, Tallinn 10122
  • Ministry of the Interior: Pikk 61, Tallinn 15065
  • Financial Intelligence Unit: Tööstuse 52, Tallinn 10416
  • Tax and Customs Board: Lõõtsa 8a, Tallinn 15176