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Estonia’s Sanctions Screening Process: A Comprehensive Overview

Estonia has a sanctions regime in place, driven by its membership in the European Union and commitment to implementing United Nations (UN) sanctions. The country’s main legislation for enforcing international sanctions is the International Sanctions Act of 2019.

Identifying Individuals and Entities Subject to Restrictions

Under this act, Estonia relies on UN and EU sanctions lists to identify individuals and entities subject to restrictions. However, the Estonian government can also implement autonomous sanctions, although it does not currently do so.

Purpose of the Sanctions Regime

The sanctions regime in Estonia is designed to prevent the misuse of international financial systems by freezing assets and imposing other restrictions on designated individuals and entities. The country’s financial intelligence unit is responsible for monitoring transactions and reporting suspicious activity.

Responsibilities of Individuals and Legal Entities

• Reporting Obligations: Individuals and legal entities are required to notify the Estonian Financial Intelligence Unit if they have reason to believe that someone with whom they are doing business is subject to an international financial sanction.
• Know Your Customer Requirements: Banks and other financial institutions are under a more stringent obligation to uphold sanctions.

Consequences for Breaching Sanctions

The consequences for breaching sanctions in Estonia can be severe, including: + Fines + Imprisonment of up to five years + Any transaction that breaches the act or related legislation is void, unless an exemption is granted and retrospective authorization is obtained.

Implementation of International Sanctions

Estonian authorities implement international sanctions through a range of administrative agencies, including: + Ministry of Foreign Affairs + Police and Border Guard Board + Ministry of Economic Affairs and Communication + Ministry of the Interior + Financial Intelligence Unit

These agencies are responsible for enforcing various aspects of the sanctions regime, such as restrictions on travel, employment, and financial transactions.

Recourse through the Administrative Court

Individuals or entities subject to Estonian sanctions can seek recourse through the Administrative Court. The court has the authority to review decisions related to sanctions and ensure that they comply with applicable laws and regulations.

Contact Information for Relevant Regulators

• Ministry of Foreign Affairs: Islandi väljak 1, Tallinn 15049, Estonia; Tel: (+372) 6 377 000; Fax: (+372) 6 377 099; Email: info@vm.ee
• Police and Border Guard Board: Pärnu mnt 139, Tallinn 15060, Estonia
• Ministry of Economic Affairs and Communication: Suur-Ameerika 1, Tallinn 10122, Estonia
• Ministry of the Interior: Pikk 61, Tallinn 15065, Estonia
• Financial Intelligence Unit: Tööstuse 52, Tallinn 10416, Estonia
• Tax and Customs Board: Lõõtsa 8a, Tallinn 15176, Estonia