Scroll to top

AML Officer for Crypto exchanges

This post was first published on Comistar Medium channel.

Crypto exchanges registered in Estonia are experiencing uncertain times. This is due to change of AML regulations which Estonia is implementing for crypto exchanges. This will also mean that all license holders will need to have activity and management functions in Estonia by the end of 2019. For many foreigners, that’s a deal breaker, and we can fully understand it.

To this date there haven’t been any public big money-laundering crimes committed by these crypto exchanges. This can’t be said about banks, though. where one scandal follows another. So the panic of the politicians is a bit weird, as they are looking to implement the new regulations as quickly as possible and without proper evaluation of the effects it may have, because it’s too urgent. But well, it isn’t the first time when politicians and officials are doing decisions about matters they have no clue about.

Every crypto exchange needs to have an AML officer. This AML officer has to have proper knowledge about Estonian AML regulations. And with the new law, this AML officer also has to reside in Estonia. Meaning, if you want to have the crypto exchange license in Estonia, you will need to have an AML officer who lives in Estonia.

At Comistar, we’ve discussed this requirement internally. On the one side, we’re not very interested in providing compliance officer services, as it’s a big responsibility and can be pretty time consuming. However, on the other side, it’s our sole purpose to provide solutions to our clients and make it possible for them to do business.

Hence, we’re now open to discuss the possibility of providing the compliance officer solutions to our clients.

Below, you can see a schema of the new requirements which the government is discussing.

If you’re looking for AML officer solutions, please get in touch with us and we’ll evaluate your business, background, and potential collaboration possibilities.

aml estonia

The management of the company has to have impeccable reputation, and the AML officer has to come to an interview with the Estonian Financial Intelligence Unit. During the interview, the required knowledge of the AML officer is determined.

AML is undoubtedly extremely important, and regulations have to be in place. Whether it’s proportional, that’s for the market to decide. It will become more difficult, hence, it will also become more valuable to hold such licenses. Hence, the quality of the companies should improve, at least in theory.

To find out more about AML requirements and the compliance officer services, please contact us at

Comistar provides business, legal and tax support for e-residency companies. Our core focus is on Fintech licensing, e-commerce companies, blockchain industry and affiliate marketers. We’ve been operating for over 5 years and have helped more than 300 companies to get started in Estonia.