The Estonian state has made about 200 exemptions to European Union and other sanctions imposed on Russia in the aftermath of its full-scale invasion of Ukraine, soon entering its twenty-second month.
An exemption can only be granted if there is both a sound legal basis and a compelling justification to do so, according to Andres Siplane, from the Ministry of Foreign Affairs' sanctions and strategic goods surveillance department.
An example of a necessary basis for exceptions includes safety considerations, such as those concerning large quantities of fertilizer, particularly bearing in mind the August 2020 Beirut explosion.
Siplane said: "When the current, full-scale war started, we had large quantities of fertilizers in ports in Estonia and which were hazardous. These were frozen (ie. left in situ - ed.) as they belonged to [Russian] oligarchs. At the same time, we needed to handle them one way or another, so that no disastrous outcome might occur.
"So, exemptions were granted in regard to the export of these fertilizer stocks," he went on.
Another consideration is transition periods between fresh sanctions being announced, such as the 12th EU sanctions package just announced, and their coming into effect.
Conversely, once exemptions have served their purpose they tend to be removed from the list.
For instance in the case of fertilizer, a significant stock which was held at the Port of Muuga, just East of Tallinn, has now been removed from Estonia, meaning the exemption is now off the table.
Those who had invested in the Russian stock market and later wished to exit from those investments were also permitted to do so, albeit at below market rates, though the deadline for doing this passed "a while back," Siplane said.
Some further exemptions may, for instance, be applied to Russian diamond imports planned for the new year.
In any case, an exemption would not be made simply to permit a Russian oligarch from accessing his or her frozen assets, the ministry spokesperson said.
There are no plans to follow Finland's lead in issuing an exemption to allow a domestic firm to sell off its Russian subsidiary, Siplane added, noting that nonetheless exemptions had been in theory viable for Estonian firms wishing to bring in otherwise sanctioned goods from Russia, if they were winding up business activities in the Russian market.
There were no such cases in practice, Siplane added.
Editor: Andrew Whyte, Mait Ots
Source: ERR Radio News, reporter Joakim Klementi.