Licences for financial services

Before you begin: Read our comprehensive blog post on what financial services licences are required for your business in Estonia

You need to apply for an activity licence if you wish to operate in the following fields of activity:

•   Operating as a financial institution (except areas of activities connected to responsibilities of the Financial Supervision Authority)
•   Providing trust and company services;
•   Providing pawnbroking services;
•   Providing a virtual currency exchange and/or wallet service;
•   Buying-in or wholesale of precious metals, precious metal articles or precious stones.

The activity of financial service providers is regulated by the Money Laundering and Terrorist Financing Prevention Act (MLTFPA).

Amendments to the MLTFPA were adopted by the Estonian parliament Riigikogu on 11 December 2019. The main purpose of the amendments is to strengthen the position of the Estonian Financial Intelligence Unit (FIU) in its authorisation and supervision procedures for digital-asset related businesses.

The main amendments are:

• The currently two different licences are merged into one virtual currency service licence with three services (i.e. exchange service and wallet service) and virtual currency to virtual currency exchange becomes regulated. The new virtual currency service licence covers the exchange from fiat-to-virtual currencies and vice versa, virtual currency to virtual currency exchange and wallet provider services;
• The state fee for the application is EUR 3,300;
• The KYC and AML compliance requirements are equaled to those of financial institutions;
• Registered office, actual business and the location of the management of the company must be in Estonia;
• The AML officer and 1 of the management board members must be an Estonian tax resident in the meaning of the Estonian Income Tax Act (a person is considered an Estonian tax resident if he/she resides in Estonia for at least 183 days within the period of 12 months or he/she has a place of residence registered in the Estonian Population Register);
• The minimum share capital is EUR 12,000, which must be paid in by way of monetary contribution (non-monetary contributions and contributions in virtual currencies are not allowed) prior to submitting the application for the acquisition of the licence;
• The FIU will have 60 days with a possible extension of up to 120 days to render the decision whether to grant a licence;
• Stricter due diligence of the management board members.

The amendments and new requirements entered into force on the 10th of March 2020

Virtual Currency Exchange Licence and E-Wallet Licence

Our company has prepared for the amendments and new requirements and is pleased to offer you two options: the essential package or the all-inclusive package.

The packages offered are in compliance with the new legal requirements and include all the necessary steps to be taken in order to get an Estonian company that is officially licenced as a provider of virtual currency services and ready to start operating.

Essential package

Service includes:

(1) Company Formation
(2) State Fee for the Licence
(3) e-Residency Card Application for the Compliance Officer
(4) Renting the Office Space
(5) Filing and Submitting the Licence Application
(6) Payment Account at a Virutal Currency Friendly PsP
(7) Notarized and Apostilled Incorporation Documents
(8) Setting Up Accounting
(9) Assistance with Share Capital Contribution

Altogether: EUR 8,600 (excl. VAT, if applicable).

All-Inclusive Package

Service includes:

(1) Company Formation
(2) State Fee for the Licence
(3) e-Residency Card Application for the Compliance Officer
(4) Renting the Office Space
(5) Filing and Submitting the Licence Application
(6) Payment Account at a Virutal Currency Friendly PsP
(7) Notarized and Apostilled Incorporation Documents
(8) Setting Up Accounting
(9) Assistance with Share Capital Contribution
(10) Signing the Lease Contract for the Office
(11) Compilation of the Employment Contract
(12) Translation of the Financial Intelligence Unit Interview
(13) Practice Interview with the Client
(14) Tax Residency Proof from EMTA
(15) VISA Application
(16) Submitting a Place of Residence to the Population Register
(17) Local Director (Member of the Management Board) and Local AML Contact Person*

Altogether: EUR 11,800 (excl. VAT, if applicable).

* Applicable only during the application process

Package includes dedicated in-house personnel during the application process. Continued provision of the service after obtaining licences is subject to additional due diligence and special conditions. We reserve the right to cancel service provision at any time without notice.

Please note that you have to pay 12, 000 EUR as share capital contribution. This is compulsory for companies dealing with virtual currencies, but it will remain for the use of company and can be used for company development, for buying capital assets, etc.

The fees have no hidden charges, thus they include all the relevant notary fees and state fees.

Read more on how to obtain a cryptocurrency exchange licence in Estonia - A Step by Step Guide!