Estonia's Financial Supervision Authority completed a large-scale test in 2024 of the automated sanctions-screening controls used by banks, payment institutions and an investment firm to identify sanctioned individuals and companies. Overall performance was assessed as generally good, but the exercise identified some filtering systems requiring additional support. The test, run with an external technology services provider, used supervisory technology to assess tens of thousands of data entries across 38 different filtering systems at 15 firms (12 banks, two payment institutions and one investment firm) against international and Estonian sanctions lists, including those of the United Nations, the European Union and the USA. The authority highlighted that technology alone is not sufficient, as sanctions experts are needed to configure and calibrate systems to each institution’s business model, and the same vendor solution can produce different outcomes across firms depending on setup.
Finantsinspektsioon 2025-03-25
Estonia's Financial Supervision Authority reports 2024 sanctions screening test found generally good results but some filtering systems need improvement
Estonia's Financial Supervision Authority conducted a large-scale test of automated sanctions-screening controls in 2024, assessing systems at 15 firms against international and Estonian sanctions lists. While overall performance was generally good, some filtering systems required additional support. The authority emphasized the need for sanctions experts to configure and calibrate systems to each institution’s business model.