A crypto license in Estonia

We help to bring your crypto project to the EU market
Send the request and get 1 month of legal support for free*
The offer is limited and valid for:
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*(10 hours per month) when ordering a Starter or Premium package
years of consulting experience in the crypto industry
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revoked crypto licenses from our clients
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95%
of our customers become a long-term partners
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By working with us, you get:
High-quality legal support
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Application for a virtual currency service provider license
State fee 3300 EUR
AML Policy preparation
Communication with FIU
Business model description and other documents for FIU
Contact person service for 1 year
Bank account opening in EMI in EEA
Registration of the place of residence for EU citizens
Employment agreement
AML officer for 6 months
Office rent for 6 months
Submit the request and get an office rental for 1 month for free*
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Regulatory changes for VASPs in Estonia

Update regarding the draft of Money Laundering and Terrorist Financing Prevention Act
There is a lot of argumentations regarding the new regulation for VASPs in Estonia. Lex Law Office will give you a short and prompt overview regarding the real situation to prepare your business for future potential changes.




draft of the law should pass 3 hearings in the Parliament before it will


The main purpose of the amendments of the current regulation is related to the Moneyval report, according to which virtual currency service providers were indicated as the riskiest industry in Estonia. The Estonian government is trying to implement the regulation, which will have more strict requirements for the VASPs to minimize the money laundering risk and make the market more transparent. Another important aspect is related to the FATF recommendations regarding VASPs and MiCA regulation, which should be implemented soon in all EU countries. As both the FATF recommendation and MiCA are having stricter requirements for the VASPs, Estonia wants to be one of the first countries in the EU, who is implementing the new regulatory regime for VASPs in Europe.

As you may know, Estonia was the first country in the EU in 2017, which started to regulate and provide the licenses for the VASPs. Now Estonia is planning to be again the number one jurisdiction in the EU, which is implementing the new rules for VASPs, which will be long-termed, customer protective, and transparent.

Main points
According to the current regulation
According to the potential regulation
State fee for the license application
3300 EUR
10 000 EUR
State fee for the change in the license application
-
4000 EUR
AML officer
Permanently working for the company, no limits for the number of the VASP companies
Permanently working for the company, working only for 1 VASP company
Member of the board
No limits regarding the number of the VASP companies
2 VASP companies, 3 companies according to special permit from FIU
Supervision fees

-
1. 0,0035% of annual turnover;
2. 1% of the share capital (annually)
Travel rule
-
Will be applicable
Transactions without verification
Up to 1000 EUR
Not allowed
Financial audit
According to the general auditing rules
Annual
Internal audit
Yes, no special requirements
Yes, special division and only certified internal auditor
The right to the temporary renouncement of the license (pause)
Yes
No
Business plan and financial forecast
Business model description
Business plan with financial forecast for 2 years
Others documental requirement
AML Policy
Sanctions Policy
Duties description
In additional:
1.Financial documentation (balance sheet, income statement, etc.)
2. Risk assessment, risk appetite
3. Description of the technology systems, IT tools and security measures
4. Description of technology measures and systems for KYC and KYT
5. Shareholders´ information
6. Shareholders´ shares information in other companies
7. Auditor and internal auditor data
Capital requirement
12 000 EUR
125 000 EUR;
350 000 EUR
(for remittance service)
Requirements for the members of the board
Sufficient knowledge and experience
Higher education
2 years' experience
Share transfer
Should inform FIU in advance

Not possible to sell more than 10% of the shares during 2 years after getting a license
Timing
According to the present text of the draft of the law, it will be effective from the 1st of February 2022.

All VASPs, who are holding the license, according to current regulation should bring the business to the new regulatory requirements until the 18th of March 2022.

Most probably the timing will change.

Conclusion
This cruel is to pay attention that a draft of the law is just presented to the Parliament, there is no clear understanding about the final text, requirements, and timing and it should pass 3 hearings. Important is to mention that regulator and the government are interested to ensure the security market for VASPs and sufficient and long-termed regulation that will be in place with the future EU regulatory regime.

Lex Law Office will be glad to assist your project to prepare for the regulatory changes and help to bring the business to the new requirements. Our team consists of the leading experts in virtual assets and compliance regulation, who are participating in the international conferences as speakers, taking part in the round table and giving an expert opinion to the government authorities and legislator regarding regulation.
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Our Contacts
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Phone
+372 5885 7575
Address
Osmussaare tee 8, Tallinn
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