Estonia

Global sanctions guide

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European Union
  1. Does Estonia have a sanctions regime in place? 

Yes.

  1. 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.

  1. 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.

  1. 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 organisations which are binding on Estonia. Estonia’s main legislation for enforcing international sanctions is the International Sanctions Act 2010 (“the Act”).

To the extent that issues are not covered by Chapter 3 (concerning the implementation of sanctions) or Chapter 4 of the Act (concerning state supervision), the relevant legislation is the Money Laundering and Terrorist Financing Prevention Act 2007.

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 persons, such as banks, are under more onerous obligations to uphold sanctions in order to “draw special attention” and “take measures”.

  1. Does Estonia maintain a list of sanctioned individuals and entities? 

No. Estonia relies on UN and EU sanctions lists.

  1. Are there any other lists related to sanctions? 

No.

  1. Does Estonia have a licensing or authorisation system in place? 

Yes. Where exemptions from trade sanctions are available, prior authorisation may be obtained from the Ministry responsible for administering the sanction. Where exemptions from financial sanctions are available, prior authorisation may be obtained from the Financial Intelligence Unit. Authorisations or refusals will be based on the conditions of the sanctions themselves.

  1. 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 5 years (Section 93 of the Estonian Penal Code).

Where a transaction breaches the Act, or legislation based upon the Act, the transaction is void (Section 11 of the Act). The exception to this is where an exemption is available and retrospective authorisation is granted. In such instances, the transaction is effective from the moment that the authorisation is granted.

Persons against whom Estonian authorities implement international sanctions have recourse through the Administrative Court.

  1. 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 9 of the Act).

The Ministry of Foreign Affairs is responsible for proposing sanctions to the government for passage into legislation, and for embargoes on arms and related material, dual use goods and technical assistance.

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 Finance is responsible for bans on imports and exports of goods, except arms, related material and dual use goods.

Ministry of Finance
Suur-Ameerika 1
Tallinn 15006
Estonia

T: (+372) 611 3558
F: (+372) 611 3664
E: info@fin.ee
www.fin.ee/

The Ministry of Economic Affairs and Communication is responsible for bans on the provision of certain services (as specified in Sections 16(1)(1) to (3) and (7) to (11) of the Act).

Ministry of Economic Affairs and Communication

Harju 11
Tallinn 15072
Estonia

T: (+372) 625 6342
F: (+372) 631 3660
E: info@mkm.ee
www.mkm.ee/

The Ministry of the Interior is responsible for restrictions on entry into Estonia and obligations to leave.

Ministry of the Interior
Pikk 61
Tallinn 15065
Estonia

T: (+372) 612 5008
E: info@sisministeerium.ee
www.sisministeerium.ee/

The Financial Intelligence Unit is responsible for financial sanctions, including the freezing of funds and economic resources, financing and financial assistance.

Tööstuse 52
Tallinn 10416
Estonia

T: (+372) 612 3840
F: (+372) 612 3845
E: rahapesu@politsei.ee
www.politsei.ee/en/organisatsioon/rahapesu-andmeburoo/

 

Contributor law firm

Maivi Ots and Toomas Pikamae, Advokaadibüroo Eversheds Ots & Co, Kentmanni 4/Sakala 10, Tallinn, 10116, Estonia