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Blockchain & Estonia

Estonia is one of the most popular blockchain hubs in Europe. Supportive tax environment, a vibrant start-up scene and favorable attitude form the government all make Estonia a top place to start and run your blockchain company.  Whether you’re opening your own trading platform or launching your token, we’ll help you to do it in a right way. Comistar is the only official partner of the e-residency program focused on blockchain industry.

Services for ICO companies (utility tokens)

White paper legal analysis. We look at the token design and features and highlight all the potential security elements, which could classify your token as a security, and therefore require complying with the securities regulations. Additionally, we look at the tax and KYC questions, and whether your business would require any licensing to comply with the Estonian (and the EU) legal framework. Together with the analysis, the client will receive comments in regards to the token model, and if required, a binding legal opinion.

The comprehensive analysis includes:

  • Security token elements
  • Whether the Securities Market Act of Estonia applies to the offering
  • Whether the business model requires licensing?
  • Elements of a “Ponzy scheme”
  • Should the token be considered as an e-money?
  • Is the token sale subject to the VAT?
  • If the token sale is subject to the VAT, when and how the VAT should be paid?
  • KYC and AML processes and requirements

Licenses that may be required, are:

  1. Service of exchanging a virtual currency against a fiat currency
  2. Virtual currency wallet service

Token Sale Agreements.

Every ICO project needs to govern the relationship with its investors and token buyers. Whether it’s a private stage, pre-ICO or a public ICO, token sale agreements are a necessary part of every token launch.

Terms & Conditions and Privacy Policy.

It’s required by the law to have and communicate the terms & conditions and privacy policy of your ICO and the website to your visitors and ICO participants.

Company upkeep and accounting. 

Our accounting staff is well experienced and focused on working with the blockchain projects – ICOs, STOs, traders, and exchanges. We also provide your company incorporation services, virtual office and other relevant support.


The prices of the legal services for the ICO projects depend on what you need. The full package is between 10 000 € – 15 000 €, but you are not obliged to order the full package. The white paper analysis is priced between 3000 € – 4500 €, dependent on the concrete white paper.


All securities will be tokens in the future. It’s a big statement, and it takes a lot of time, but this is the future that we see. 2018 was the year when the first security token offerings were conducted, and in 2019 the activity in the STO sphere has only increased.

What is a security token? It’s a tokenised security, with all the security elements. A security token is backed by external, tradable assets, and can represent a real share of the company. Security tokens give you ownership rights, whereas utility tokens are more like a gift card for company products/services.

All security token offerings are regulated offerings, unless financial exclusions apply (the amount raised is below 2 500 000€, maximum 150 investors per Member State, minimum of 100 000€ investment possible).

We help to structure the offering, choose the right type for the security, write a compliant prospectus, register the prospectus, and advise you throughout the security token offering process.

On our Medium channel, you can find articles on security token offerings and regulations.

Additional services


We have platform partners that help our clients to do media promotion, PR, raise funds, and take care of the technical part of the WP. These services include, but are not limited to, designing the token, analyzing the whole business model, writing the technical part of the white paper, providing the whole KYC solution and the ICO back- office (bounty programs etc).

Crypto company & fintech licenses


We have a special package called “Crypto company”, which means that we’ll help you to set up a legal entity with cryptocurrency exchange and e-wallet licenses in Estonia. These licenses are specifically issued for cryptocurrency exchanges that want to offer fiat to crypto exchanging possibility to its clients. Comistar has set up crypto companies for clients all over the world.

Time-frame for setting up a crypto company is about 30 working days.

Price: Upon request

Read full description of obtaining the licenses HERE


Companies looking to provide payment gateway services, money remittance services, online banking solutions or issue their own credit card or electronic money, need to obtain the e-money institution or the payment services license, dependent on their business model. Minimum required capital is 350 000 €, and it takes generally 8 – 10 months to obtain the license. Both licenses are passportable financial services in the EU.

Price: Upon request.

Some of the clients

"Easily the best e-Residency service provider out there"