Financial Crime World

Estonia’s Sanctions Regime: A Comprehensive Overview

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Tallinn - Estonia has a sanctions regime in place that follows the restrictive measures laid down by the United Nations (UN), the European Union (EU) and other international organizations. In this article, we will provide an overview of Estonia’s sanctions regime, including its implementation, enforcement, and consequences.

Implementation of Sanctions

Estonia implements UN sanctions through directly applicable regulations as a member of the EU. The country relies on UN and EU sanctions lists to identify individuals and entities subject to financial and trade restrictions. However, Estonia has its own legislation in place to enforce international sanctions, including:

  • International Sanctions Act 2019 (the Act)
  • Money Laundering and Terrorist Financing Prevention Act 2017

Notification Obligations

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

  • Licensing and Authorization System
    • Estonia has a licensing and authorization system in place for exemptions from trade and financial sanctions.
    • Prior authorization may be obtained from the relevant ministry or the Financial Intelligence Unit, depending on the type of exemption sought.

Consequences of Breaching Sanctions

Breaching Estonian sanctions can result in severe consequences, including:

  • Fines
  • Imprisonment for up to five years
  • Voiding transactions that breach the Act or legislation based upon it

Enforcement Agencies

Responsibility for enforcing international sanctions is shared among various 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
  • Tax and Customs Board (responsible for banning the import and export of goods)

Contacting Regulators

Individuals seeking to understand Estonia’s sanctions regime can contact the relevant regulators at the following addresses:

  • Islandi väljak 1, Tallinn 15049
  • Pärnu mnt 139, Tallinn 15060
  • Suur-Ameerika 1, Tallinn 10122
  • Pikk 61, Tallinn 15065
  • Tööstuse 52, Tallinn 10416