Most professionals in financial crime compliance come from law enforcement, audit or legal backgrounds. Siiri Graabi took a different route, arriving via the European Council, where she spent more than a decade as an Estonian diplomat. Her time in Brussels put her in the room as EU sanctions packages were being negotiated and drafted.
According to Salv, Today, Graabi serves as sanctions and counter-terrorism financing officer at Coop Bank in Estonia, giving her a rare dual perspective. She has witnessed why sanctions are shaped by political urgency, diplomatic compromise and midnight deadlines, and she now understands what it takes to implement and enforce them on the front line.
Speaking on a recent episode of Salv’s Follow the Money podcast series with host Dr Nicola Harding, Graabi discussed her career, Estonia’s Salv-powered model of cross-institution intelligence sharing, and what the rest of Europe must grasp before the AMLR Article 75 and PSR Article 83 deadlines land in 2027.
Estonia’s banks have been exchanging financial crime intelligence via Salv Bridge for over five years. What began as an informal working group within the Estonian Banking Association, with banks comparing notes on sanctions hits and flagging fraud over messaging apps, evolved into a real-time, structured, encrypted and legally grounded system with a full audit trail. Graabi chairs the association’s sanctions working group, which convenes banks, supervisors and regulators monthly to align on implementation and share evasion patterns. That group laid the foundation for the Salv Bridge network.
One use case she outlined shows the system’s speed. A sanctions screening alert flags a potential name match, and Graabi sends a request to another Estonian bank covering date of birth, citizenship and place of residence. Within minutes, an answer arrives and the payment is released or blocked with a documented rationale. Fraud cases operate similarly: when defrauded funds move to another institution, an immediate message allows the receiving bank to freeze the account. Millions of euros have been recovered through such joint investigations, including funds routed through virtual IBANs that typically drain out of Europe within hours.
On the 2027 deadline, Graabi was frank that the timeline is already tight. Coop Bank sanctions and counter-terrorism financing officer Siiri Grabbi said, “You need the passionate crime fighters to build it. There needs to be somebody who provides the platform who has the mission to do something. Is there a legal ground in place in the country, or do they wait for the regulations to kick in? Are the politicians ready? How do they interpret GDPR? It’s so easy to say GDPR doesn’t allow [sharing], but not all data [falls under] GDPR.”
The barriers, she argues, are not primarily technical but stem from legal uncertainty, internal policy alignment, infrastructure readiness and the willingness to begin before every question is resolved. Estonia started, learned and expanded rather than waiting.
Addressing the most common misconception, Grabbi said, “That we all want to get the other banks’ clients to ourselves. But it’s not the case. I don’t want a criminal to become my client. I just want to receive the information and intelligence to know if my doubts are correct.” In her experience, the competitive instinct holding institutions back is misplaced, as intelligence sharing stops bad money moving rather than handing customers to rivals.
Her advice to compliance officers elsewhere in the EU begins with a mindset shift: sharing compresses investigation time, produces fuller reports and creates the audit trail supervisors increasingly expect. To public authorities, her message is direct — stop treating the private sector as an adversary, engage industry earlier in drafting regulation, and lead by example. As for what Estonia did right, she said, “We started straight away.”
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