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New Crypto Regulation Changes In Estonia?

New Estonian crypto regulation changes
  • The draft law was created by the old government. Many people in the Ministry of Finance have changed. My colleagues from another firm have had several meetings now with the people from the Ministry of Finance, and there’s a light at the end of the tunnel.
  • Finance of Estonia, the association of FinTech market participants, ordered a lengthy analysis on the proposed changes together with more reasonable proposals from a top law firm.
  • The proposed draft law was somewhere between unreasonable and moronic. Especially the proposed time-frames for existing license holders.

Proposed Changes

  • the share capital of at least EUR 25,000, or a quarter of the previous year’s fixed costs;
  • a registered location and head office located in Estonia;
  • the management board must consist of at least two persons;
  • the management board must have an impeccable business reputation, knowledge, skills, experience, education and professional suitability for the management of the service provider. This knowledge, skills and experience must include aspects such as understanding the technology on which the service is based, preventing and avoiding risks, protection of customers’ interests, the preservation of financial stability and avoidance of illegal activity;
  • a business plan;
  • balance sheet and statement of income, expenses, profits, losses and cash flows and, if available, the accounts for the last three financial years (if applicable);
  • internal rules corresponding to the requirements in the act;
  • internal accounting rules;
  • information concerning the information technology systems and other technological means and systems necessary for the provision of the planned services, including a description of the security measures used to ensure continuity of service and the level of technical organisation of activities;
  • security policy, or rules and information on ensuring security, including measures to ensure cyber-security;
  • internal control rules and rules of procedure which ensure the fulfilment of obligations in connection with the prevention of money laundering and terrorist financing (this requirement already applies), now including financing of the activities of the applicant;
  • a description of the applicant’s organisational structure;
  • a list of shareholders, with identification details (already applies today);
  • information on the qualifying holding;
  • information on the managers of the applicant, including identification information, details of residence, a description of their education, a complete list of jobs and positions held, and, in the case of members of the management board, a description of their area of ​​responsibility, as well as supporting documents which the applicant considers relevant (already applies today);
  • information concerning companies in which the participation of the applicant or a member of its management body exceeds 20 per cent;
  • information concerning the audit firm and internal auditor of the applicant;
  • documents certifying the number of own funds, together with a sworn auditor’s report;
  • a list of payment accounts held in the name of the service provider (already applies today).
  • Application fee to decrease but annual supervision fee will apply

What Will Happen?



Business, tax & legal, licensing and a lot more. All posts are written by Comistar professionals around the world. Doing business in Estonia, Switzerland, Finland and the US.

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