Current requirements for the cryptocurrency (VASP) virtual currency service providers in Estonia

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Below is a list of the requirements to register as a cryptocurrency virtual currency service provider under the current laws:

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• the company’s share capital must be at least EUR 12,000;

• the registered office of the company, the seat of the management board and the place of business must be in Estonia 

• the management board must be of good repute;

• the company must appoint a compliance officer who works permanently in Estonia and has the appropriate level of skills, knowledge and experience to perform the role of a compliance officer; 

• internal procedures with regard to AML and KYC;

• the company; members of its management body; and its beneficial owner(s) must be fit and proper; and,

• the company must have a client account with a credit institution (bank), an electronic money institution or a payment institution established in Estonia.

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New requirements for virtual currency service (VASP) providers

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Under the new requirements, service providers must have/provide, among other things, the following:

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• the minimum share capital of at least EUR 25,000, or a quarter of the previous year’s fixed costs;

• a registered physical office and head office located in Estonia;

• the management board must have an impeccable business reputation, be fit and proper, and have  knowledge, skills and experience;

• the management board must consist of at least two people;

• a business plan;

• financial forecasts, including your balance sheet and statement of income, expenses, profits, losses and cash flows;

• internal rules relating to the requirements of Estonian legislation;

• details of your internal accounting policy and procedures;

• details of your information technology systems, including a description of your security measures;

• security policy and information on ensuring the security of your payments;

• internal control rules and rules of procedure relating to the prevention of money laundering and terrorist financing;

• a description of your organisational structure (organisational hierarchy chart);

• details of each of your shareholder(s);

• details of the key people e.g. managers, within your firm;

• details of your auditor and internal audit arrangements; and,

• certification of your own funds.

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Application fee for the cryptocurrency (VASP) virtual currency licence in Estonia

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The current application fee payable is EUR 3,300. Under the new regime, the application fee will be reduced to EUR 1,000.

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Timeframe to obtain the cryptocurrency (VASP) virtual currency licence in Estonia

 

The EFSA must process all new applications within 3 months of receipt of all required documents if the application is complete with all the required documents submitted. Where this is not the case, it can take up to 6 months.

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How we can help set up your crypto business in Estonia

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Buckingham Capital Consulting can advise you on the most appropriate and suitable licence, based on your business model and plans. We can prepare, manage and obtain your licence in the country of your choice and help you understand your regulatory and legal obligations. 

 
Our service involves the following:

- Guiding you through the application preparation stage
- Managing the entire application from planning to obtaining the licence
- Preparing, completing and submitting the application form
- Submitting the individual directorship forms
- Submitting your application to the financial regulator
- Assisting you with any correspondence/further questions from the financial regulator after submitting your application until your licence has been granted.  

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