Estonia’s AML/CTF supervisors
Banks, insurance companies and intermediaries, investment firms, fund managers, investment and pension funds, payment institutions, creditors and credit intermediaries, and the securities market are all subject to state supervision by Finantsinspektsioon as they all operate under activity licences that this regulatory body has issued
As the body responsible for financial supervision, Finantsinspektsioon works to prevent money laundering by keeping an eye on financial intermediaries as part of its oversight duties. Its main duty is to make sure that the organisation and risk management of banks and other financial intermediaries adopt procedures and systems that are in line with their business plan, risk, and staffing levels. If Finantsinspektsioon discovers evidence of money laundering or terrorism financing while conducting its oversight, it informs the Estonian Financial Intelligence Unit (FIU).
The Finantsinspektsioon's supervision efforts are divided between capital supervision and market and service supervision. The purpose of financial supervision is to uphold the reliability of the Estonian financial system by ensuring the stability and level of service provided by businesses that offer financial services.
How do you comply with AML/CTF regulations in Estonia?
You must do a risk assessment as an obliged entity that considers at least the following categories:
Risks involving your clients
Risks associated with the nations, regions, or jurisdictions you are dealing with
Risks associated with your transactions, services, or goods
Risks associated with interactions, transactions, products, services, or delivery methods between you and your customers
You must perform the following risk assessment in addition to the one mentioned above:
Establish procedural guidelines that permit efficient risk reduction and management regarding money laundering and terrorism financing
Work together to combat money laundering and terrorism financing with other required parties, state supervisory agencies, and law enforcement
Oversee the Anti Money Laundering and Terrorist Financing Prevention Act, appoint a member to the management board (where you have more than one management board member)
Apply due diligence procedures when beginning a business connection and whenever you mediate or participate in transactions that occasionally occur outside of a business relationship and include cash payments of more than 15,000 euros or an equivalent amount in another currency
Establish guidelines for keeping a commercial partnership under review
Include a description of the transaction along with the date of the transaction or period
What are my AML/CTF reporting obligations?
You must alert the FIU if you notice any actions or circumstances that could point to money laundering or terrorism financing, or if you have reason to believe that such behaviour has already taken place. Within 2 working days of identifying the act or the circumstances giving rise to the suspicion, the notification must be submitted.
You must also inform the FIU of any transaction where the cash payment of an equivalent amount in a different currency exceeds 32,000 Euros. Irrespective of whether the transaction is carried out in a single payment or numerous connected payments, the notification must be sent within 2 working days of the transaction's execution.
