Higher Risk
 
Medium Risk
 
Info n/a
 
Lower Risk
Bilateral exchange of
information Agreements in
place?
Double taxation agreement with exchange of
info agreement with the Isle of Man.
Sanctions:

As a member of the EU, the country is party to all EU Sanctions
as well as UN sanctions.

____________________________________________________

Offshore Jurisdiction Blacklists:

Information unavailable.

____________________________________________________

US State Department Money Laundering Report - 2011:

Estonia has one of the most transparent, developed banking
systems of the new European Union (EU) members. Estonia has
adopted the universal banking model, which enables credit
institutions to participate in a variety of activities such as leasing,
insurance, and securities. Transnational and organized crime
groups are attracted to the territory due to its location between
Eastern and Western Europe. Analysis of suspicious transaction
reports (STRs) discloses some incidents of transferring the
proceeds of Internet crime to Estonia. There have been no
reports of terrorist financing in Estonia.

DO FINANCIAL INSTITUTIONS ENGAGE IN CURRENCY
TRANSACTIONS RELATED TO INTERNATIONAL NARCOTICS
TRAFFICKING THAT INCLUDE SIGNIFICANT AMOUNTS OF US
CURRENCY; CURRENCY DERIVED FROM ILLEGAL SALES IN
THE U.S.; OR THAT OTHERWISE SIGNIFICANTLY AFFECT THE
U.S.: NO

CRIMINALIZATION OF MONEY LAUNDERING:

“All serious crimes” approach or “list” approach to predicate
crimes: All serious crimes

Legal persons covered: criminally: YES civilly: YES

CRIMINALIZATION OF TERRORIST FINANCING:

Ability to freeze terrorist assets without delay: YES

UN lists of designated terrorists or terrorist entities distributed to
financial institutions: YES

(Please refer to the Department of State’s Country Reports on
Terrorism, which can be found here: http://www.state.
gov/s/ct/rls/crt/)

KNOW-YOUR-CUSTOMER RULES:

Covered entities: Credit and financial institutions, lottery/gambling
institutions, real estate firms, traders who receive payments in
cash that exceed 200,000 kroons (approximately $20,000),
pawnbrokers, auditors and accountants, tax advisors, service
providers for trust funds and business associations, notaries,
attorneys and legal advisors, bailiffs, and trustees in bankruptcy

Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: YES

SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:

Covered entities: Credit and financial institutions, lottery/gambling
institutions, real estate firms, traders who receive payments in
cash that exceed 200,000 kroons (approximately $20,000),
pawnbrokers, auditors and accountants, tax advisors, service
providers for trust funds and business associations, notaries,
attorneys and legal advisors, bailiffs, and trustees in bankruptcy

Number of STRs received and time frame: 3,475 from January to
September 2010 (714 related to terrorist financing)

Number of CTRs received and time frame: 6,777 from January to
September 2010

MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:

Prosecutions: Not available

Convictions: 29 persons from January to November 2010

Assets forfeited: criminally: Not available civilly: Not available

RECORDS EXCHANGE MECHANISM:

With U.S.: YES

With other governments/jurisdictions: YES

Estonia is a member of MONEYVAL, a Financial Action Task
Force (FATF)-style regional body. Its most recent mutual
evaluation can be found here: http://www.coe.
int/t/dghl/monitoring/moneyval/Evaluations/round3/MONEYVAL%
282008%2932Rep-EST3_en.pdf

ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:

Estonia is member of the EU, and on January 1, 2011, joined the
euro zone. On March 8, 2010, the Auditors Activities Act came
into effect, and on October 5, 2010, the International Sanctions
Act took effect. On April 12, 2010, Estonia became a party to the
UN Convention against Corruption. Estonia should continue to
enhance its AML/CFT regime, as necessary.

____________________________________________________

US State Dept Narcotics Report 2012:

Estonia’s domestic anti-narcotics legal framework is in full
compliance with UN drug conventions and European Union
narcotics regulations. The Estonian Narcotic Drugs, Psychotropic
Substance and Precursor Act has been in force since 1997.
Except for a higher HIV-infection rate among intravenous drug
users (IDUs) in Estonia, the drug situation in Estonia is similar to
that in other European countries. Estonia is a party to the 1988
UN Drug Convention, the UN Convention against Corruption and
the UN Convention against Transnational Organized Crime.

A new extradition treaty between the United States and Estonia
entered into force on April 7, 2009, replacing the 1924
agreement. The new agreement is in compliance with agreements
previously signed between the EU and the United States, as well
as with a 2002 decision of the EU Council concerning arrest
warrants and transfer procedures. The United States and Estonia
are parties to a mutual legal assistance agreement which entered
into force on October 20, 2000. Both governments have also
ratified and exchanged instruments regarding a Protocol to the
MLAT. These instruments form the basis for a modern law
enforcement regime and implement obligations under the U.S.-EU
extradition and mutual legal assistance agreements.

The Government of Estonia (GOE) does not encourage or
facilitate illicit production or distribution of narcotic drugs and
psychotropic substances, nor does it encourage or facilitate the
laundering of proceeds from illegal drug transactions. Combating
the trade, production and domestic consumption of narcotics
continued to be high priorities for all Estonian Law enforcement
agencies and for key government ministries in 2010-11. The GOE
has excellent cooperation on counter narcotics efforts with all
neighboring countries. The Estonian Tax and Customs Board
(ETCB) and the Estonian Police and Border Guard Board
maintain good international cooperation through liaison officers
with Finnish, Swedish, German, and UK customs and police
authorities and with DEA. In March after a high-level meeting the
chiefs of Estonian and Finnish police, border guard and customs
renewed the cooperation agreement focusing on cross-border
organized crime, drug trafficking and illegal immigration.

Approximately 80 police officers from the Estonian Police and
Boarder Guard Board (EPBGB) specialize solely in narcotic-
related crime. Relations between Estonian police, tax and customs
authorities and the regional DEA office in Copenhagen have been
outstanding and productive. In Estonia the DEA has been able to
work jointly with Estonian authorities on cases of mutual interest
and share criminal intelligence. Cooperation with DEA continued
to be smooth and mutually beneficial in 2011.

Fifteen Estonian traffickers were arrested around the world in the
first ten months of 2011, down from 29 in 2010. The Estonian
police successfully investigated and charged several persons
suspected of recruiting drug smugglers and credit these efforts
with the decrease of arrests of Estonian drug traffickers abroad.
Further, according to the police, their continuous law enforcement
efforts have resulted in the number of seizures of narcotic
substances decreasing.

Approximately 420 ETCB officers perform narcotics control on a
daily basis. About 50 officers work in mobile units and 30 officers
from the Investigation Department are specialized in narcotics-
related crimes. On the European Union’s easternmost border
customs control is performed 24/7. All customs border points are
equipped with X-ray machines and equipment to disassemble
vehicles. Both border points and mobile units are equipped with
rapid drug test kits, endoscopes, fuel pumps and densimeters to
discover secreted drug caches. All customs investigation and
information officers have received special training in narcotics
control. The ETCB also has 17 drug sniffing dogs working on the
EU external border, in Tallinn airport, and in Tallinn harbor trained
to detect cocaine, heroin, amphetamine, cannabis, marihuana,
hashish, ecstasy, phentanyl and other dangerous drugs. The
ETCB also utilizes automated license plate surveillance systems
to gather additional information at border crossings.

Staff of NGOs providing services to IDUs report that most kinds of
common narcotics can also be found in Estonia. However,
opiates, synthetic drugs, and heroin are the most popular illegal
substances used domestically. According to GOE and NGO
estimates, there are about 14,000 IDUs in Estonia.

Estonia continues to implement its 2004-2012 National Strategy
on the Prevention of Drug Dependency. There are more than 60
governmental, non-governmental and private entities working with
IDUs to provide services to decrease demand and reduce harm
from drug abuse. In Estonia, there are ten drug rehabilitation
centers: two for adolescents, two for adults, six therapeutic
communities for adults and one daycare center for double
diagnosis patients. Six organizations in eight cities provide out-
patient counseling services that include psychotherapy,
psychological, social and peer-counseling services. Methadone
substitution treatment is provided by six clinics at nine different
sites. One program specializes in providing integrated methadone
substitution and Anti-AIDS Retroviral treatment for HIV - infected
IDUs. In total, nine organizations operate at 36 syringe exchange
sites including outreach teams and mobile units. According to the
National Institute for Health Development, the estimated coverage
on syringe exchange is 52 per cent of targeted IDUs as the
exchange points have about 7400 regular clients. There are no
precursor chemical control issues in Estonia.

For Full report, click here

____________________________________________________

US State Dept Trafficking in Persons Report 2011
(introduction):

(Tier 2 Watch List)

Estonia is a source, transit, and destination country for women
subjected to forced prostitution, and for men and women
subjected to conditions of forced labor. Estonian women from
rural areas are forced into prostitution in Tallinn. Women from
Estonia are found in sex trafficking situations in Finland, the
Netherlands, the United Kingdom, Germany, and Italy. Young
Estonian women forced into marriage abroad after promises of
employment were also vulnerable to trafficking in persons. Men
and women from Estonia are subjected to conditions of forced
labor in Spain, Sweden, Norway, and Finland.

The Government of Estonia does not fully comply with the
minimum standards for the elimination of trafficking; however, it is
making significant efforts to do so. Despite these efforts, the
government did not demonstrate evidence of increasing efforts
over the previous reporting period; therefore, Estonia is placed on
Tier 2 Watch List. No victims participated in prosecutions this
year, and victims reported being frightened and traumatized
during police interrogations. Although the government had
committed to the enactment of a comprehensive anti-trafficking
law in prior reporting periods, it did not pass a criminal anti-
trafficking law during the reporting period. Estonia remains the
only European Union country without a trafficking-specific law.
Those trafficking offenders convicted under non-trafficking
statutes avoided accountability; all trafficking offenders convicted
under Article 133 received suspended sentences this year. The
Estonian government, however, gave some financial support to
NGOs who care for trafficking victims, and it developed a national
action plan with elements addressing trafficking in persons.

For full report click here

____________________________________________________

US State Dept Terrorism Report 2009

Estonia actively enforced all EU laws regarding counterterrorism
and cooperated fully with the United States in law enforcement
matters. Estonian passports issued since May 2007, including
“gray” passports issued to stateless residents of Estonia, have
the latest in biometric security features, including an embedded
computer chip containing biometric information.

Participation in the International Security Assistance Force (ISAF)
operation in Afghanistan was Estonia’s highest priority
international mission. Estonia contributed an additional motorized
infantry company in 2009, for a total of two companies plus staff
officers and support elements, which equaled more than 280
soldiers. One unit formed part of a U.K.-led provincial
reconstruction team in Helmand Province, and the additional
company, also in Helmand, operated side-by-side with U.S.
Marines providing election security. Although the second
company was withdrawn, Estonia still had approximately 155
troops in Afghanistan at the end of 2009. Estonia participated in
the European Police Mission to Afghanistan with two police
officers and a political advisor. It was projected to give a total of
1.3 million Euros in assistance for the period 2009-2011, which
includes funding for the fight against narcotics; the Afghanistan
Population and Housing Census project; and for human capital
and infrastructure development of Helmand province’s health care
network, such as training of nurses, mid-wives, and other health
professionals. While no longer participating in combat operations
in Iraq, Estonia continued to support the NATO Training Mission
in Iraq with a staff officer.

On March 11, Estonia amended the Penal Code to criminalize the
financing and support of acts of terrorism or actions leading to the
perpetration of an act of terrorism, punishable by up to 10 years
imprisonment or the liquidation of any entity used in such efforts.
The MLTFPA also harmonized Estonian law with EU standards
and brought Estonia’s money laundering regime into total
compliance with Financial Action Task Force recommendations.

On October 12, the Government of Estonia began operating U.S.
Department of Energy-funded radiation monitors at Luhamaa, on
its southeastern border with Russia. The Estonian Border Guard
was in the process of constructing helicopter landing pads at
entry control points at Narva, in the east, and Varska, in the
southeast, with U.S. Department of Defense Counternarcotics and
Terrorism funds.
Tables & Rankings
Are there Sanctions in force against it? (UN/EU/US)
N
?
Is it on FATF list of non-cooperative countries?
N
?
Is it on OECD list of uncooperative Tax Havens?
N
?
OECD - Implementation status of Tax Standard
White
?
Is it on EU 'white' list of equivalent jurisdictions?
EU
?
Offshore Finance Center (Original IMF List)?
N
?
Is it on the US Secretary of Treasury list of jurisdictions of
Primary Money Laundering concern?
N
?
Is it on the US Secretary of State list of jurisdictions
identified to be supporters of International Terrorism?
N
?
Is it on US Department of State International Narcotics
Control Majors List?
N
?
US Dept of State Money Laundering assessment (INCSR)
M
?
Government Actions (For further info see INCRS below):
 
?
-  Criminalized Drug Money Laundering?
Y
 
-  Criminalized Beyond Drugs?
Y
 
-  Record Large Transactions?
Y
 
-  Maintain Records Over Time?
Y
 
-  Report Suspicious Transactions?(NMP)?
Y
 
-  Egmont Financial Intelligence Units?
Y
 
-  System for Identifying/Forfeiting Assets?
Y
 
-  Arrangements for Asset Sharing?
Y
 
-  Cooperates with International Law Enforcement?
Y
 
-  International Transportation of Currency?
Y
 
-  Ability to Freeze Terrorist Assets w/o Delay?
Y
 
-  Disclosure Protection "Safe Harbor"?
Y
 
-  Criminalized Financing of Terrorism?
Y
 
-  States Party to 1988 UN Convention?
Y
 
-  International Terrorism Financing Convention?
Y
 
 
Ranking
2011
Ranking
2010
 
Corruption (Transparency International)
29 (out of
183)
26 (out of
178)
?
Ease of doing business (World Bank)
24 (out of
183)
17 (out of
183)
?
FATF 40 + 9 recommendations
Mutual Evaluation Report: 2008
Further Tables
C
L
P
N
N/A
    C  -  Fully Compliant ,   
    L  -  Largely Compliant,    
    P  -  Partially Compliant    
    N  -  Non-Compliant
8
27
12
1
1
Legal Systems
 
1. Money Laundering Offence
L
 
14. Protection & no tipping-off
C
2. ML offence – mental element and
corporate liability
C
 
15. Internal controls,
compliance & audit
L
3. Confiscation and provisional
measures
L
 
16. DNFBP – R.13-15 & 21
P
4. Secrecy laws consistent with the
Recommendations
L
 
17. Sanctions
P
5. Customer due diligence
L
 
18. Shell banks
L
6. Politically exposed persons
L
 
19. Other forms of reporting
C
7. Correspondent banking
L
 
20. Other NFBP & secure
transaction techniques
C
8. New technologies & non
face-to-face business
P
 
21. Special attention for
higher risk countries
N
9. Third parties and introducers
L
 
22. Foreign branches &
subsidiaries
L
10. Record keeping
L
 
23. Regulation, supervision
and monitoring
L
11. Unusual transactions
P
 
24. DNFBP - regulation,
supervision and monitoring
P
12. Designated Non-Financial
Businesses and Professions – R.5,
6, 8-11
P
 
25. Guidelines & Feedback
P
13. Suspicious transaction reporting
L
     
Institutional and other
measures
 
26. The FIU
C
 
31. National co-operation
L
27. Law enforcement authorities
C
 
32. Statistics
L
28. Powers of competent authorities
C
 
33. Legal persons – beneficial
owners
L
29. Supervisors
L
 
34. Legal arrangements –
beneficial owners
N/A
30. Resources, integrity and training
L
 
 
 
International Co-operation
 
35. Conventions
L
 
38. MLA on confiscation and
freezing
L
36. Mutual legal assistance (MLA)
L
 
39. Extradition
L
37. Dual criminality
L
 
40. Other forms of
co-operation
C
Nine Special
Recommendations
 
SR.I Implement UN instruments
P
 
SR VI AML requirements for
money/value transfer services
L
SR.II Criminalise terrorist financing
P
 
SR VII Wire transfer rules
L
SR.III Freeze and confiscate terrorist
assets
P
 
SR.VIII Non profit
organisations
P
SR.IV Suspicious transaction
reporting
L
 
SR.IX Cross Border
Declaration & Disclosure
P
SR.V International co-operation
L
 
 
 
*Please note that FATF deems that a country has significant aml deficiencies if any
of the 'Core' Recommendations, R1, R5, R10, R13, SRII, or SRIV are rated either
Partially of Non-Compliant. These are marked in red.

For FATF to remove a country from the regular follow-up process, it has to be rated
Compliant or Largely Compliant in the above mentioned Core Recommendations
and the following Key Recommendations: -        

R3, R4, R23, R26, R35, R36, R40, SRI, SRIII, SRV

Please also note that any risk assessment should take into consideration all
follow-up reports.
ESTONIA
KnowYourCountry
-  Know Your Customer Provisions
Y
 
-  Criminalized Tipping Off?
Y
 
-  Report Suspected Terrorist Financing?
Y
 
-  State Party to United Nations TOC?
Y
 
-  State Party to United Nations CAC?
Y
 
________________________________________________________

AML News / Updates

May 1, 2011  -  New report by the Global Forum on Transparency and
Exchange of Information to evaluate the country's legal and regulatory
frameworks for re exchange of information is made available.

Read Report....


Links:

Worldwide AML Legislation (International Bar Association)
Local AML News / Sanctions
Tax Information
Business Information
Last Updated:   16 April 2012