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New amendments to requirements in operation of crypto companies

9 April 2020
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New amendments to requirements in operation of crypto companie


Since the adoption of the 5th Anti-Money Laundering Directive (AMLD5) Estonian companies dealing with cryptocurrencies are subject to acquisition of licenses for providing services related to crypto exchanges and crypto wallets. The  legal improvements of AML regulations are aimed to enhance the transparency and sustainability of companies engaged into financial activities. Alongside to that, these changes consequently affect the national supplementary legislation.


Recently, the Estonian Financial Intelligence Unit (Rahapesu Andmebüroo or RAB) has introduced new requirements for crypto-dealing companies that are compulsory for compliance by July 1, 2020. Otherwise, the companies’ authorisation for the mentioned activity will be revoked. The companies are obliged to provide the following documents:


  1. Copies of all of the identity documents in cases if a member of a management boards, beneficial (individual) owner has several citizenships;
  2. Duly legalised or apostilled copies of criminal records certifying the absence of convictions in commitment of crimes against state authorities, money laundering offence or another wilfully committed criminal offence. Note: in case of multi-citizenship, such documents have to be acquired from each state  of citizenship;
  3. Copies of documents certifying the level of education, full employment history (including employers), field of responsibility of each member in the management board;
  4. The list of company’s payment accounts including the data about their unique features of such accounts and their managers’ names;
  5. Other documents that upon company consideration may prove the trustworthiness of board’s members and/or company’s good business reputation.

The necessary documents have to uploaded through the online system of Majandustegevuse register (MTR) or submitted via notary.

In view of corporate structure, the companies will have to:

  1. Increase share capital to the amount of not less than 12 000 EUR;
  2. Appoint a responsible person for the application of financial sanctions as well as provide the contact details of such person.
  3. Introduce the instructions on Rules of Procedure and internal control rules.

In order to avoid the invalidation of company’s license for the provision of cryptocurrencies-related services, it is advised to carry out the newly established requirements by July 1, 2020 or earlier. Our lawyers are able to provide with any kind of the appropriate, effective and high quality assistance in relation to the implementation of the mentioned requirements, ranging from consultancy to helping with submission of documents (for both e-residents and non-resident persons) as well as depositing of share capital etc.


Besides that, we will be happy to assist in other relevant spheres, such as

  • Selection and renting an office in Estonia;
  • Selection of Director that is an Estonian resident;
  • Director’s trainings on the recent KYC/AML requirements.

Our lawyers have a significant experience in providing legal support to a wide range of issues in financial sector. If you have any inquires, do not hesitate to contact us via any convenient way at

T: +370 67 240 090

F: +371 67 240 091


For questions, please, contact Valters Gencs, attorney at law at

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The material contained here is not to be construed as legal advice or opinion.

© Gencs Valters Law Firm, 2016
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