Three general typologies are used for evading sanctions through virtual assets: direct or peer-to-peer model, intermediary model, and escrow model. The overview describes these three models and identifies indicators that refer to a heightened risk of sanctions evasion. The risk indicators for sanctions evasion have been selected based on both Estonian and international practice. The end of the overview presents the key factors for ensuring compliance that help mitigate risks.
According to § 54 section 1 subsection 5 of the Money Laundering and Terrorist Financing Prevention Act, the Financial Intelligence Unit's tasks include informing the public about preventing and detecting money laundering and terrorist financing; compiling and publishing a consolidated overview at least once a year. The Financial Intelligence Unit fulfils this task by publishing an annual report, providing feedback to market participants, conducting studies, and, since December 2022, issuing typology notices.
