1. Does Estonia have a sanctions regime in place?
2. Does Estonia implement UN sanctions?
Yes. Estonia is a member of the European Union, which implements UN sanctions in all member states by way of directly applicable regulations.
3. Does Estonia implement an autonomous sanctions regime?
No. It is possible for the Estonian government to implement autonomous sanctions, but it does not do so.
4. What is the nature of the sanctions regime in Estonia?
Estonia follows the restrictive measures laid down by the UN, the EU and other international organizations which are binding on Estonia. Estonia’s main legislation for enforcing international sanctions is the International Sanctions Act 2019 (“the Act”).
To the extent that issues are not covered by Chapters 2 and 3 (concerning the implementation of sanctions) or Chapter 5 of the Act (concerning state supervision), the relevant legislation is the Money Laundering and Terrorist Financing Prevention Act 2017.
Where international sanctions are not directly effective in Estonia, they are passed into law by way of government act. For example, an arms embargo is implemented through the Strategic Goods Act 2011. Such acts are proposed by the Ministry of Foreign Affairs.
In relation to financial sanctions, individuals and legal entities must notify the Estonian Financial Intelligence Unit if they know or suspect that someone with whom they are doing business, or are planning to do business, is the subject of an international financial sanction. Some people, such as banks, are under more onerous obligations to uphold sanctions in order to “draw special attention” and “take measures.”
5. Does Estonia maintain a list of sanctioned individuals and entities?
No. Estonia relies on UN and EU sanctions lists.
6. Are there any other lists related to sanctions?
7. Does Estonia have a licensing or authorization system in place?
Yes. Where exemptions from trade sanctions are available, prior authorization may be obtained from the Ministry responsible for administering the sanction. Where exemptions from financial sanctions are available, prior authorization may be obtained from the Financial Intelligence Unit. Authorizations or refusals will be based on the conditions of the sanctions themselves.
8. What are the consequences for a breach of sanctions in Estonia?
The consequence for breach of sanctions, whether by act or omission, is a fine or imprisonment for up to five years (Section 931 of the Estonian Penal Code).
Where a transaction breaches the Act, or legislation based upon the Act, the transaction is void (Section 7 of the Act). The exception to this is where an exemption is available and retrospective authorization is granted. In such instances, the transaction is effective from the moment that the authorization is granted.
Persons against whom Estonian authorities implement international sanctions have recourse through the Administrative Court.
9. Who are the relevant regulators in Estonia and what are their contact details?
Responsibility for international sanctions in Estonia is shared between various administrative agencies (Section 11 of the Act).
The Ministry of Foreign Affairs is responsible for proposing sanctions to the government for passage into legislation.
Ministry of Foreign Affairs Islandi väljak 1 Tallinn 15049 Estonia
T: (+372) 6 377 000 F: (+372) 6 377 099 www.vm.ee/en/
The Ministry of Economic Affairs and Communication is responsible for the provisions of services other than financial services and goods-related services.
Ministry of Economic Affairs and Communication Suur-Ameerika 1 Tallinn 10122 Estonia
The Financial Intelligence Unit is responsible for financial sanctions, including the freezing of funds and economic resources, financing and financial assistance.
The Financial Intelligence Unit
Tööstuse 52 Tallinn 10416 Estonia
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