The FIU is the competent authority regarding financial sanctions and restrictions related to public procurement. Consequently, it is not necessary to notify the FIU if a transaction is identified or reasonably suspected to relate to a violation of another type of sanction that is not a financial sanction (ISR indicator 5). Suspicions or threats of violations of import and export prohibitions must be reported to the Estonian Tax and Customs Board, and suspicions or threats of violations of international sanctions related to services must be reported to the Consumer Protection and Technical Regulatory Authority. Reports must still be submitted to the FIU if an obliged entity suspects money laundering in connection with the violation or evasion of international sanctions.
ISR reports no longer need to be submitted to the FIU if an obligated person decides to apply non-binding sanctions to Estonia, e.g., those imposed by the USA or the UK (ISR indicator 4). However, it is worth remembering when applying due diligence measures, that being listed on certain sanctions lists is a warning sign that should be assessed.
Changes are reflected in the FIU's reporting system from July 31. The reporting system is accessible only on the new address https://rabis-web.fiu.ee from July 29 onwards.
