AML officer is the contact person for the Estonian Financial Intelligence Unit, who will answer directly to the board of the company. The AML officer is either employed or part of the structural unit, i.e company board of directors. The AML officer has to notify the FIU if the company isn’t following the AML regulations.
Estonian crypto regulatory environment hasn’t been the most stable in 2020. Perhaps it’s because the old rules were too liberal. In March, new requirements came into force requiring all companies to appoint Estonian resident to the board of the company, as well as have operational IBAN account, 12 000€ as a minimum share capital, and a local office.
All crypto companies had to have an AML officer with the old rules as well, and changes that took effect in March didn’t change that. The AML officer could reside outside of Estonia as well, as long as the person had an impeccable reputation (no criminal history), higher education and preferably some industry experience.
Local AML Officer for Crypto Exchanges
However, this will change now in July 20th, 2020. After the regulatory changes take effect, the AML officer has to reside in Estonia as well, making it more complicated to be compliant for the crypto exchanges. This is not a major issue as long as the company has funds to employ the AML officer, as this person will also help exchanges to follow all the applicable AML regulations.
This new requirement will also apply to the funds and investment firms (for the majority of the fund and investment firm types it was already mandatory before, but there were exceptions) or to any other financial institution.
Interestingly, there haven’t been any notifications about the new changes neither from the FIU nor the EFSA. It’s odd, as it’s a standard to notify market participants about the upcoming regulatory changes. Before the changes that took place in March, the FIU sent out at least 2-3 emails.
Regardless, the local AML officer will be an added requirement for the crypto exchanges.
Where to find an AML Officer in Estonia?
Finding an AML officer can be pretty difficult, as there’s a high demand for the position from the banking industry as well from various crypto exchanges. Currently, at the time of the writing, we have 7 qualified AML officers to provide to potential clients seeking for the Estonian license.
Get in touch with us at [email protected] for more information.