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By Maya Lester KC & Michael O’Kane

EU Licensing

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Estonia

S.13 of the International Sanctions Act governs licensing (authorisations).

Applications should be submitted to the relevant competent authority which grants or refuses the application within 30 days of the submission of the application. The relevant competent authority responsible for licensing varies according to the restriction/sanctions in place.

Relevant competent authorities are as follows:

  • restrictions related to financial sanctions and public procurements – the Financial Intelligence Unit;
  • entry ban – the Ministry of the Interior;
  • restrictions on the stay, residence and employment – the Police and Border Guard Board;
  • ban on the import and export of goods – the Tax and Customs Board;
  • restriction relating to accounting, auditing, accountancy, tax consultancy, business consultancy, management consultancy, public relations, architectural, engineering, legal, tourism, media, information society and advertising services, market research and public opinion polling services, technical testing and analysis services and information technology consultancy services – Consumer Protection and Technical Regulatory Authority;
  • restriction relating to a vessel, aircraft or motor vehicle – the Transport Board;
  • ban on entry into the inland sea and port – the Defence Forces;
  • prohibition related to the registration of a company/directors disqualification – the registration department of Tartu County Court.

In the case of financial sanctions – applications should be sent to info@fiu.ee using the Exemption application form. The Money Laundering Information Bureau may then grant the exemption.

The competent authority may, in justified cases, extend the time limit for processing the application by up to 60 days. The extension of the time limit is notified in writing to the applicant. The grant of the authorisation is coordinated with the Ministry of Foreign Affairs.

Priority is given to applications for the granting of authorisation for provision of humanitarian aid.

Authorisations may be issued with terms and conditions that the applicant is required to comply with upon providing the authorised service or carrying out the transaction/action.

 

General Authorisations:

The Financial Intelligence Unit (FIU) has granted a general authorisation for the partial release of funds for the payment of necessary and extraordinary expenses for the management of the company’s assets. The Estonian Money-Laundering Information Bureau has issued corresponding general permits to the following legal entities: EuroChem Terminal Sillamäe Private Limited Company (issued on 4.07.2022)

  • TT Baltics SIA Estonian branch (issued on 29.09.2022)
  • Social Welfare Department of the Embassy of the Russian Federation (issued on 01.03.2024)

Germany

The Deutsche Bundesbank is responsible for granting sanctions licences.  The Federal Office for Economic Affairs and Export Control is responsible for granting import and export licences.

Latvia

The Financial Intelligence Unit (FIU) is responsible for granting licences to permit activity that would otherwise be prohibited by national or international sanctions regimes. See our export control section for information on export control licences.

An activity will only be licensed where the national or international sanctions instrument (usually an EU regulation) provides grounds for it. Applicants for licences should submit a written application to the FIU containing the following:

  • Information about the transactions or activity for which the permit is requested;
  • Information on the relevant sanctions framework;
  • An assessment of the compliance of that transaction with the specific exception;
  • Information about directly related transactions and activities necessary to execute the primary transaction; and
  • Any other information that is necessary.

Legal entities registered in Latvia applying for a sanctions licence must submit additional information about their business and employees. Full information on licensing procedures is at Part VI of Cabinet of Ministers Regulation No. 184.

For more information about sanctions licensing in Latvia, see the FIU’s Frequently Asked Questions.

Malta

Individuals and entities may apply to the Sanctions Monitoring Board using the template form (linked below) for a licence to allow an activity, service, or transaction to take place that would otherwise be prohibited under EU or UN restrictive measures.

Sanctions Monitoring Board Applications for Derogations

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