Estonia

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In Estonia, for activities in the field of cryptocurrency and digital assets' services, in accordance with the Law on the Prevention of Money Laundering and the Financing of Terrorism, a license is required, called a single cryptocurrency license.  Two different services fall into this category: a virtual currency wallet service provider and a virtual currency exchanger.  Previously to 2020, they required two different licenses, but beneficially have now been merged into the single Virtual Currency Service Provider License. Once a license is approved it covers the following areas.

1) Crypto-wallets and custodian services 

• The first category of services includes the generation and storage of encrypted customer keys.

2) Crypto-exchange 

• The second category of services is the cryptocurrency exchange for fiat money or vice versa, or cryptocurrency for another cryptocurrency.

The minimum capital requirement for a Virtual Currency Service Provider License, is EUR 12,000.  This amount must be deposited in fiat money and not crypto currency, and, must be present in the Estonian company accounts prior to lodging the application. 

If engaging in the business of a virtual currency service provider, you must have a physical presence in Estonia.  You must have a director of the company located in Estonia and of Estonian Nationality.  Each person on the board must pass fit and proper tests and be approved persons by the regulator.  In addition, the KYC/AML officer will have to undergo an interview with the FIU to confirm their skills and suitability for the position. 

The experience and qualifications of the personnel constitute one of the most important elements of a successful application.  It is very important to be able to locate and select qualified individuals, who would constitute the minimum required key personnel of your firm.  And, these individuals must be approved by the regulator.

We can handle all relevant subjects which include selection of the personnel, immigration and work permits if necessary, drafting employment contracts and, most importantly, check adequacy of the candidates against the key position in your firm.  

The regulator requires you to disclose most all aspects and details of your business. Our business is to ensure you meet the regulator's requirements, and we will review what you currently have or complete what is needed for you.

• Business and Financial Plan
• Supervisory and AML/CTF Manuals
• KYC of beneficial owners, directors, controllers and affiliates
• Proof of Professional Indemnity Insurance

• Capital adequacy requirements must be calculated regularly
• Annually, an audited financial statement
• Monthly, interim financial statements prepared in accordance with generally accepted accounting principles
• As needed, any material changes to the firm, its operations or people

Estonia is home to some of the world's most innovative fintech companies and there are a number of banks serving the financial services sector.  We will facilitate bank introductions and account openings.

Estonia is a major fintech center and hosts many of the participants in the financial services industry. Estonia is becoming recognized throughout the world as a crypto-currency hub with an extensive crypto ecosystem.  We will facilitate and establish the institutional relationships you need to build a successful business.

When you engage with us, our scope of service covers all of the aspects you need in order to get your crypto licence:

• Provision of regulatory guidance
• Company incorporation
• Approved Person’s fit and proper tests
• Employing local directors, officers and staff
• Establishing an office
• Facilitating bank accounts
• Introduction to accountant and auditor relationships
• Management and supervision of the application
• Preparation of all client-facing legal documents including client business terms and disclosures
• Completing the business plan, compliance manuals, employment and outsourcing agreements  

3 to 4 months.