# Estonian PEP legal scope and date semantics

Reference date: 2026-08-18.

## Controlling official sources

1. Money Laundering and Terrorist Financing Prevention Act (RahaPTS), especially § 9¹ and § 41(3):
   - current Estonian consolidation located through Riigi Teataja: https://www.riigiteataja.ee/akt/113022026013
   - official English consolidation: https://www.riigiteataja.ee/en/eli/515122023007/consolide
2. Minister of Finance Regulation No. 34, *List of Estonian positions whose holders are considered politically exposed persons*, consolidated wording effective from 17 October 2022:
   - https://www.riigiteataja.ee/akt/114102022002
3. Constitution of Estonia, §§ 61, 81 and 91:
   - https://www.riigiteataja.ee/en/eli/ee/523042025001/consolide
4. Government of the Republic Act, oath/assumption rule:
   - https://www.riigiteataja.ee/en/eli/502012023006/consolide
5. Status of Members of the Riigikogu Act, § 3 and mandate-resumption provisions:
   - https://www.riigiteataja.ee/en/eli/516042015001/consolide

## Statutory definition and former-holder treatment

RahaPTS § 9¹(1) defines a PEP as a natural person who performs or has performed prominent public functions **and with regard to whom related risks remain**.

RahaPTS § 41(3) states that once the person no longer performs the function, an obliged entity must take the remaining risks into account **for at least 12 months** and continue relevant risk-sensitive measures until it is certain that PEP-characteristic risks no longer exist.

This is not an automatic two-year legal period. Twelve months is the minimum risk-treatment period; continuation after that is risk-based and has no fixed statutory maximum.

## Exact national position list

Regulation No. 34 treats the holders of these Estonian positions as PEPs:

1. President of the Republic;
2. Prime Minister;
3. minister;
4. member of the Riigikogu;
5. member of the management board of a political party;
6. State Secretary;
7. secretary general/chancellor of a ministry;
8. Auditor General;
9. Chancellor of Justice;
10. Justice of the Supreme Court;
11. Prosecutor General;
12. Chair and members of the Supervisory Board of Eesti Pank, and Governor and Deputy Governors of Eesti Pank;
13. Ambassador Extraordinary and Plenipotentiary, envoy and chargé d’affaires;
14. Commander of the Defence Forces;
15. Commander of the Defence League;
16. member of the supervisory board or management board of a company under the controlling influence of the state;
17. supervisory-board and management-board members of: North Estonia Medical Centre Foundation; Tartu University Hospital Foundation; Enterprise and Innovation Foundation; Rural Development Foundation; Environmental Investment Centre Foundation; and the State Forest Management Centre (RMK);
18. mayors of Tallinn, Tartu, Narva, Pärnu and Kohtla-Järve, and the mayor of Saaremaa Rural Municipality;
19. Directors General of the Education and Youth Board, Internal Security Service, Defence Resources Agency, Language Board, Environmental Board, Competition Authority, Land Board, Tax and Customs Board, National Heritage Board, Patent Office, Police and Border Guard Board, Agriculture and Food Board, Agricultural Registers and Information Board, Rescue Board, State Agency of Medicines, Information System Authority, Social Insurance Board, Statistics Estonia, Consumer Protection and Technical Regulatory Authority, Health Board, Transport Administration and Foreign Intelligence Service;
20. Directors General of the Data Protection Inspectorate and Labour Inspectorate;
21. Directors General of the State Shared Service Centre and Emergency Response Centre, and the State Archivist of the National Archives;
22. members of the Supervisory Board and Management Board of the Financial Supervision Authority;
23. Director of the Financial Intelligence Unit.

It additionally covers the heads of these accredited international organisations located in Estonia:

- Baltic Defence College;
- NATO Cooperative Cyber Defence Centre of Excellence;
- NATO Force Integration Unit Estonia (the Regulation’s “NATO staff element”).

## Start-date rule

Announcement or nomination alone does not make someone the **holder** of a listed office and does not by itself establish that they perform the function. The operative event must be determined from the law governing the particular office:

- President: Constitution § 81 — assumes office upon taking the oath before the Riigikogu. Election is recorded separately but is not the office start.
- Government/minister: Constitution § 91 and Government of the Republic Act — assumes office upon taking the oath. A presidential appointment before the oath is recorded separately.
- Riigikogu: Constitution § 61 and Status of Members of the Riigikogu Act § 3 — mandate commences when the election results are announced; substitute/restored mandates commence under the applicable National Electoral Committee or Riigikogu Board decision. The oath precedes performance of duties but is not the statutory mandate-start date.
- Ambassador Extraordinary and Plenipotentiary: Foreign Service Act § 27(6) — after agrément, the President appoints the candidate as ambassador and signs the credentials. Record the presidential decision date as the domestic legal appointment event; do not replace it with the act-publication date. Presentation of credentials, arrival/posting, and public announcement are separate events and must be retained separately when they are used to establish actual assumption/accreditation. Under § 41(2), the President also performs the legal recall; recall decisions must not be backfilled from a successor’s appointment.
- Other positions: use the effective date specified by the appointment/election instrument or the office-specific statutory assumption rule. Where the official evidence gives only an announcement or appointment but not the effective commencement, the actual-start field must remain blank.

## Future officeholders

An announced, nominated, elected or appointed person whose office-specific legal commencement event has not occurred is listed separately as `announced-future`, not as a current holder. An already-serving incumbent who has been appointed to a future consecutive term remains current under the existing tenure; the future term is a separate future record until its effective date.