Overview
Estonia is a UN and EU Member State and so implements UN and EU sanctions. It also has its own autonomous sanctions. The legal basis for these sanctions is the Estonia International Sanctions Act.
EU/UN Sanctions:
Estonia gives effect to EU and UN sanctions under §§8&9 of the International Sanctions Act. The Ministry of Foreign Affairs is the competent authority responsible for overseeing sanctions implementation and cooperating with other ministries and competent authorities.
Autonomous Sanctions:
By § 27 of the International Sanctions Act, Estonia imposes sanctions by regulation on the proposal of the Ministry of Foreign Affairs. The Ministry has a website dedicated to sanctions imposed by the Government of Estonia. Sanctions are to support objectives set out in the International Sanctions Act:
- 3(1) (supporting the maintenance or restoration of peace, international security, democracy and the rule of law, following human rights and international law or achieving other objectives of the United Nations Charter or the Common Foreign and Security Policy of the European Union)
- 4 (to protect the security or interests of Estonia) of the International Sanctions Act
Autonomous sanctions include:
- a restriction on the granting of visas, short-term work in Estonia and temporary residence permits for the purposes of work, study or entrepreneurship to citizens of the Russian Federation and the Republic of Belarus
- an entry ban into Estonia on a list of designated people in view of the situation in Belarus
- an entry ban into Estonia applying to Hizballah members
- an entry ban into Estonia applying to a list of designated people to ensure compliance with human rights
- a restriction on the provision of services to Yandex NV, which is prohibited from providing services related to the organization of taxi transport, taxi transport brokerage and these services in Estonia
In March 2025, Estonia also sanctioned: Viatcheslav Moshe Kantor, a Russian Israeli businessman; Gulbakhor Ismailova, the sister of Russian businessman, Alisher Usmanov; and Mikhail Degtyaryov, the Russian sports minister. All 3 were removed from the EU’s Russia sanctions list on 14 March 2025. Estonia adopted a Regulation imposing in Estonian law the same sanctions (asset freezes and travel bans) as had previously been imposed by the EU.
National Competent Authorities
S.10 of the International Sanctions Act explains the role of the Ministry of Foreign Affairs (the main ministry responsible for sanctions) in Estonia’s sanctions. Other ministries initiate the procedure for the legislation necessary for the implementation of international sanctions in their area of government and must ensure the necessary conditions for the implementation and application of international sanctions in their area.
The relevant competent authority responsible for licensing varies according to the restriction/sanctions in place:
- Financial Intelligence Unit & Money Laundering Information Bureau–financial sanctions
- Ministry of the Interior – entry bans
- Police and Border Guard Board – restrictions on stay, residence and employment
- Tax and Customs Board – bans on the import and export of goods
- Ministry of Economic Affairs and Communications – bans on the provision of services other than financial services and goods-related services
- Transport Administration – restrictions on vessels, aircraft or motor vehicles
The following bodies are involved in enforcement:
Legislation
Sanctions Lists
Estonia Government sanctions in view of the situation in Belarus
Guidance
Licensing
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)
Enforcement
Chapter 6 of the International Sanctions Act and § 931 of the Estonian Penal Code governs enforcement of sanctions.
If a person knowingly performs services for a person/entity subject to sanctions, they risk a fine or up to 5-years imprisonment An entity that does the same will be fined. The offence is classified as an offence against humanity and international security.
The following are classified as misdemeanours and are punishable by detention (no more than 30 days) or fines of up to €1200 when committed by a person, or a fine of up to €400k when committed by an entity:
- failure to notify the FIU of the identification of a subject of financial sanctions or a transaction violating financial sanctions
- failure (by a financial or credit institution) to appoint a board member responsible for notifications to the FIU
- failure to identify and update a risk assessment for international sanctions
- failure to apply due diligence measures when establishing/during a business relationship
- failure to establish and comply with rules of procedure and internal control rules and failure of employee of person with special obligations (see Reporting) to implement them
- breach of an obligation to provide (additional) information
Violations of reporting obligations or obligations to collect/store data are punishable by a fine (up to €1200 for people and €400k by entities).
Violations of prohibitions on the import and export of goods/cash under international or autonomous sanctions is punishable by the following where the value does not exceed €10k: a fine of up to €1200 for people and €400k for entities.
The following bodies are involved in enforcement:
Reporting
Reporting suspected sanctions violations:
By § 133 of the International Sanctions Act, credit institutions are required to notify:
- the Tax and Customs Board of any suspicion or threat of a violation of the prohibition on import or export of goods imposed by international sanctions, and
- the Consumer Protection and Technical Regulatory Authority of any suspicion or threat of a violation of international sanctions related to a service.
Under § 19 of the International Sanctions Act, a person or entity who is aware that a person/entity who has or is planning to have a business relationship with them is a subject of financial sanctions, or a transaction or act intended or carried out by that person violates financial sanctions, must notify the Financial Intelligence Unit immediately.
By § 21 of the International Sanctions Act, ‘persons with special obligations’ (defined in §20 as including financial institutions, providers of virtual currency services, and auditors, etc) are required to verify whether the person who has or is planning to have a business relationship with them is a subject of financial sanctions. In case the person with special obligations identifies such a person, the person with special obligations must immediately inform the FIU. Under § 22 of the Act, the person is also required to collect and store data for 5 years (from termination of a business relationship).
By § 321, the person with special obligations is also required to report to the FIU information on persons, funds, economic resources, accounts, payments and transactions and other relevant data which is necessary for the implementation and application of financial sanctions.
Notifications should be submitted electronically to the FIU.
Guidelines for submitting a report to the financial intelligence unit
Explanatory guidelines on reporting to the FIU
Asset reporting obligations in EU’s Russia sanctions:
By article 9(2) of EU regulation 269/2014, people and entities listed in Annex I to the Regulation are required to report before 1 September 2022 or within 6 weeks from the date of listing, funds or economic resources within the jurisdiction of Estonia belonging to, owned, held or controlled by them, to the competent authority of Estonia (the Financial Intelligence Unit) where those funds or economic resources are located; and cooperate with the FIU in any verification of such information
The FIU provides a recommended form for the submission of this information.
Judgments
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Aleksandr Ivantsov sentencing sanctions violations
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Andrei Klychkov sentencing export violations
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Demyan Belyakov sentencing sanctions violations
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Ruslan Sibilev sentencing sanctions violations
