Estonia's Comprehensive Approach to Combat Money Laundering

Estonia's Comprehensive Approach to Combat Money Laundering

February 23, 2024·Makhmud Efendi
Makhmud Efendi
From Intelligence Gathering to International Cooperation: Unveiling Estonia's Strategic Defense Against Financial Crimes
Estonia's Comprehensive Approach to Combat Money Laundering

This article delves into Estonia’s multifaceted strategy to safeguard its financial system against money laundering and terrorism financing. Highlighting the pivotal roles of the Estonian Financial Intelligence Unit, Estonian Financial Supervision Authority (EFSA or Finantsinspektsioon), and investigative agencies, it explores the rigorous measures in place for monitoring, prevention, and enforcement. With a focus on international collaboration and the innovative use of the Legal Entity Identifier (LEI) code, the piece offers an in-depth look at Estonia’s commitment to financial integrity and the global fight against illicit financial activities.

Ensuring the stability and transparency of Estonia’s financial system necessitates continuous efforts to combat money laundering and terrorism financing. This crucial endeavor is spearheaded by the Estonian Financial Intelligence Unit, Finantsinspektsioon (the Estonian Financial Supervisory Authority), and investigative authorities, each with clearly defined legal obligations.

Financial Intelligence Unit

What is FIU?

The Financial Intelligence Unit (FIU) is an independent structural unit of the Police and Border Guard Board whose main duties are gathering, registration, processing, and analysis of information referring to money laundering and terrorist financing (i.e. reports and information submitted by all the entities required to comply with the law), as well as tracing of criminal proceeds and strategic analysis that covers the risks, threats, trends and ways of operation of money laundering and terrorist financing.

Investigative functions

In certain cases, the Financial Intelligence Unit also performs the duties of an investigative body. The FIU verifies whether the data submitted to it is important for countering, identifying, or pre-trial investigation of money laundering, related criminal offenses, and terrorist financing. The FIU analyses and verifies information about suspicions of money laundering and terrorist financing, takes measures for the preservation of property where necessary, and immediately forwards materials to the competent authorities (e.g. Prosecutor’s Office) upon identification of elements of a criminal offense.

Supervisory functions

The FIU also has supervisory functions. The FIU supervises compliance with the requirements of the Estonian MLTFPA and legislation adopted on the basis thereof concerning the obliged entities required to comply with the MLTFPA that are not subject to the supervision by the EFSA, the Estonian Bar Association (attorneys) or the Ministry of Justice (notaries). The FIU also issues authorizations to its supervision subjects. In addition, the FIU exercises state supervision over compliance with the International Sanctions Act (incl. financial sanctions). In connection with this obligation, the FIU shall publish the information about the imposition, amendment, or termination of international financial sanctions or shall make it available on its webpage.

Who are obliged entities?

Obliged entity means a person specified in the §2 of the MLTFPA.
LEIpapa recommends reviewing official sanctions lists every single time before initiating any business transaction with the new counterparty. Find the updated information on Sanctions Lists and Resources.


The Financial Intelligence Unit plays a pivotal role in the oversight of money laundering activities, gathering data, and scrutinizing earnings from criminal endeavors. It possesses the authority to obtain information concerning transactions, individuals, and activities suspected of being linked to money laundering or terrorist financing from the EFSA, other governmental and local entities, and, under certain conditions, private individuals.

Investigative Agencies

Investigative agencies, including the Police and the Prosecutor’s office, are tasked with identifying, investigating, and prosecuting money laundering cases, and forwarding evidence of criminal conduct to the judiciary. The courts then determine guilt and assign penalties accordingly.

In the system of money laundering and terrorist financing prevention, these are authorities that hold the right in criminal proceedings by having the obligation to conduct criminal proceedings if facts referring to a criminal offense become evident (incl. in the role of an investigative body) and by having the right to perform (pre-trial) acts related to criminal proceedings. The functions of the Estonian Internal Security Service are mostly related to terrorist financing prevention. Thus, the above authorities are competent to conduct proceedings on money laundering criminal offenses and decide on conviction for criminal offenses (court).

Financial Supervision Authority

EFSA’s contribution to anti-money laundering efforts primarily involves the regulation and monitoring of financial intermediaries through its supervisory functions. It ensures that the management structures and risk management practices of banks and other financial entities are adequately designed to align with their business strategies and associated risks. This encompasses a wide range of services, including credit issuance, payment and investment services, and insurance, emphasizing the importance of the know-your-client principle in mitigating money laundering risks.

While EFSA’s role is to oversee operational systems and processes, it does not adjudicate on specific instances of money laundering. Should evidence of such activities be discovered during its regulatory duties, it is mandated to report these findings to the Financial Intelligence Unit as per legal requirements.

International Connections

Internationally, Estonia actively participates in committees and working groups dedicated to setting and evaluating standards for combating money laundering and terrorist financing, collaborating closely with entities like the MONEYVAL committee of the Council of Europe and the European Banking Authority’s anti-money laundering group.

EFSA, in partnership with the European Central Bank, oversees major Estonian banks and independently regulates smaller financial institutions, while the supervision of branches of EU banks outside the eurozone in Estonia falls under the jurisdiction of the respective home country’s regulatory body.

ML&TF Prevention and Supervision Framework

Step 1: Information Gathering

This involves collecting data from various sources, including on-site and off-site inspections, ensuring information accuracy, and consolidating data for analysis.

Step 2: Risk Analysis

The input is analyzed to map and assess risks, which aids in the planning of supervisory measures.

Step 3: Supervisory Actions

Depending on the entity’s cooperation level and the situation’s specifics, actions may include discussions on rectifying potential violations, issuing directives to address or prevent violations, or, in severe cases, revoking licenses.

In cases of suspected money laundering, EFSA notifies the Financial Intelligence Unit and/or the Prosecutor’s Office.

Strategic Objectives

Preventing money laundering and terrorist financing remains a strategic priority for the EFSA, utilizing risk-based supervision as a cornerstone of its approach. The proportion of non-resident clients within a bank’s portfolio serves as a key risk indicator in this context. The case of Danske Bank’s Estonian branch, with its significant non-resident clientele, underscores the importance of stringent oversight and the effectiveness of the EFSA’s supervisory measures in identifying and rectifying non-compliance with anti-money laundering regulations.

The ongoing commitment to combating money laundering is a continuous process, requiring constant vigilance and adaptation to emerging threats.

Legal Entity Identifier (LEI) Against the Money Laundering

In this ongoing battle against money laundering, the introduction and enforcement of the Legal Entity Identifier (LEI) code stand out as pivotal measures. The LEI is a critical tool for enhancing transparency in financial transactions, allowing for the clear identification of corporate entities involved in financial dealings.

Its role in preventing money laundering is indispensable, as it ensures that all financial organizations can be easily and accurately identified, thereby closing the gaps that illicit actors might exploit. Discover who can apply for an LEI and how to easily search LEI codes with LEIpapa search tool.

For the integrity of the global financial system and to meet regulatory requirements, securing an LEI is essential for all financial institutions. This step not only contributes to the broader efforts to prevent money laundering but also reinforces the trust and safety of financial operations worldwide.

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At LEIpapa, we understand the importance of a Legal Entity Identifier (LEI) in today’s interconnected global economy, and we’re committed to making your registration process as smooth and hassle-free as possible. Visit LEIpapa web app or contact us to start your LEI registration today.

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