Published joint analysis: “Evolving Payment Landscape and AML Challenges in the Baltic States”

21.05.2026 | 10:41

The Estonian Financial Intelligence Unit, in cooperation with the Financial Intelligence Units of Latvia and Lithuania, has published a joint analysis on payment service providers and AML/CFT risks across the Baltic States, covering the period from 2021 to the first half of 2024. It shows that each Baltic State has a distinct risk profile shaped by the structure of its customer base, the nature of financial services provided, and geographical positioning.

“The analysis confirms that some payment service clients are moving to neobanks or to other payment and e-money service providers that are less regulated than banks. A continuing concern is the non-transparent provision of correspondent services to crypto-asset service providers,” said Toomas Plaado, Deputy Head of the Estonian Financial Intelligence Unit.

The analysis concludes that financial flows across the Baltic States are closely interconnected and increasingly supported by cross-border and digital financial services. This development further highlights the importance of regional cooperation and a coordinated, risk-based approach to the monitoring of financial flows and AML/CFT risks across the Baltic States. “We are committed to cooperation with our colleagues in Latvia and Lithuania to ensure that we have a clear and up-to-date overview of money laundering risks in the region,” said Plaado.

“Evolving Payment Landscapes and AML Challenges in the Baltic States” is based on financial institution survey data from Estonia and Latvia, national payment statistics from Lithuania, publicly available information, and financial intelligence. It builds on the trilateral Baltic cash flow analysis published in 2023 and reflects continued regional cooperation in addressing evolving financial crime risks.

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