To apply for the above mentioned cryptolicenсe, it must be done via a company registered in Estonia or through a registered branch office of a foreign company in Estonia.
We help with registering a company and drafting the document set required for the license with submission to FIU.
During the licence application process we assist in communication with FIU as it often has additional questions or demands clarifications.
In case of a foreign corporate shareholder, FIU requires the criminal record of the foreign company and every related person of that legal entity. FIU also requires to provide the foreign registry extract with the list of UBOs of the relevant entity. Thus, using a foreign company in the Estonian company makes the licensing process more complicated.
FIU can invite the contact person (i.e. AML compliance officer) for a face to face meeting before granting the licence. The goal is to confirm that the person in charge is familiar with the AML rules of procedure, relevant Estonian laws and obligations to notify FIU in case of money laundering or terrorism financing suspicion. In case the AML compliance officer is not in the structure of the Estonian company (in the board or shareholding), FIU wants to see employment relation.