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AML Estonia: FIU - Rahapesu Andmebüroo Requirements

Executive Summary

 This page is a practical guide to Estonia AML compliance for financial institutions—covering AML software in Estonia, goAML Estonia (STR filing), and sanctions screening in Estonia, with clear legal and supervisory expectations.

Last Updated: 2025-09-09


Estonia’s AML/CFT framework is anchored in the Money Laundering and Terrorist Financing Prevention Act (RahaPTS), which implements EU AML directives. The Financial Intelligence Unit (FIU, Rahapesu Andmebüroo) receives suspicious transaction reports via the goAML system and coordinates with other authorities, while Finantsinspektsioon supervises banks, insurers, e-money/payment institutions, and investment firms. Obliged entities must apply a risk-based approach across the lifecycle: robust CDD at onboarding and ongoing monitoring, identification and verification of beneficial owners (BO), PEP screening and EDD, prompt STRs to the FIU, compliance with UN/EU financial sanctions, comprehensive recordkeeping, and strong internal controls and governance. Finantsinspektsioon also monitors adherence to the International Sanctions Act, ensuring effective sanctions controls alongside AML requirements.


Estonian financial institutions leverage the H3M KROTON compliance platform to meet these obligations efficiently. The KROTON suite (including KYC Miner, Sanctions Miner, Scenario Manager, Link Miner, the Rumi adverse media search tool, and Case Manager) digitizes and automates key compliance workflows. For example, KROTON auto-verifies customer identities and risk profiles during onboarding, screens clients and transactions against sanctions and PEP lists in real time, and continuously monitors account activity against risk-based scenarios. Alerts and cases are managed through an integrated dashboard, allowing compliance officers to investigate and document STR filings with full audit trails. By centralizing customer data, due diligence documentation, and audit logs, the platform enables Estonian banks and fintechs to fulfill AML/CFT requirements more effectively and demonstrate compliance to regulators. In summary, Estonia’s regulatory framework imposes rigorous AML standards, and KROTON’s end-to-end compliance capabilities help financial institutions meet these FIU filing and oversight obligations with greater efficiency and transparency.

TABLE OF CONTENTS

 

  • Customer Due Diligence (CDD) – 4
  • Beneficial Ownership (BO) – 5
  • Politically Exposed Persons (PEPs) & Enhanced Due Diligence (EDD) – 8 
  • Risk-Based Approach (RBA) – 10 
  • Ongoing Monitoring of Business Relationships – 12 
  • Suspicious Transaction Reporting (STR) – 15 
  • Sanctions & Terrorist Financing (TF) Controls – 17 
  • Recordkeeping & Retention – 19 
  • AML/CFT Program & Independent Audit – 22
     

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Frequently Asked Questions

 Immediately once reasonable grounds for suspicion are formed—Estonian law requires reporting “without delay,” generally interpreted as within two working days of detecting the suspicious activity. STRs are filed electronically through the FIU’s goAML portal, and institutions must avoid tipping off the customer during the reporting process.


 At least five years under Estonian law (RahaPTS). Financial institutions must keep all customer due diligence files, transaction records, and STR documentation for a minimum of 5 years (typically from the end of the customer relationship or transaction) to ensure information is available for any regulatory review.


 Estonia does not mandate a separate Currency Transaction Report (CTR) with a fixed threshold like some jurisdictions. However, any unusual transaction over €32,000 with no apparent lawful purpose must be reported to the FIU within two working days of detection. This effectively serves as a de facto large transaction reporting requirement in the absence of a formal CTR rule.


 Estonian banks must screen customers and transactions against the United Nations, European Union, and relevant domestic sanctions lists. If a true match to a designated person or entity is confirmed, the institution must immediately freeze the assets or block the transaction and promptly inform the competent authorities (usually the FIU and/or Finantsinspektsioon) as required by law.


 Financial institutions must apply enhanced due diligence measures for Politically Exposed Persons. This includes obtaining senior management approval before establishing or continuing a business relationship with a PEP, determining the PEP’s source of wealth and source of funds, and conducting enhanced ongoing monitoring of the relationship. These steps ensure higher scrutiny and oversight for PEP clients in line with Estonian regulatory expectations.


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