30+

AML Officers recruited for our clients

60+

Licenses obtained for our clients

2500+

Clients served from various industries

5+

Years of experience with providing legal assistance for crypto companies

Open your crypto company in Estonia

Estonia is known as a digital nation and has been on the forefront of innovation for two decades. Estonia is one of the few countries in Europe to have a specific license for cryptocurrency service providers.

Process of obtaining the Estonian crypto license (after March 15, 2022)

1

Recruiting the necessary personnel and establishing the company with local substance (Estonian local managers, AML officer, employees, clients, office, etc.).

2

Opening the bank account in EEU and depositing the required share capital amount. The share capital must be a minimum of 100 000€ or 250 000€ depending on the business model.

3

Drafting the business plan and financial projections for at least two subsequent years.

4

Drafting the risk assessment and risk appetite statement.

5

Implementing the real-time risk analysis (“Travel Rule”).

6

Drafting the license documentation (AML policies, business continuity plan, IT systems description etc.).

7

Appointing an internal auditor to perform the tasks of the internal audit activity.

8

Submitting the balance sheet and annual report audit.

9

Submitting the license application to FIU.

Definition

Estonian crypto license description

License covers virtual currency-based exchange, trading, transfer, e-wallet services, initial coin offering (ICO) and any provision of related financial services. Estonian license is required for both fiat to crypto activities and crypto to crypto activities. E-wallet providers can generate and keep encrypted keys on the behalf of the client, i.e., providing custodial services of the required credentials to access the virtual currencies.

Timeframe

Time for getting licensed

The usual time frame for getting a crypto license in Estonia is 3-5 months, starting from scratch. After the company is incorporated it takes approximately 1 month to draft and collect necessary documentation. The FIU decides whether to grant a license within 60 to 120 working days after the receipt of all required documents and information.

Bank Account

Opening the bank account for the Estonian crypto company

Opening the bank account for companies doing business in the crypto industry is one of the most complicated issues. The account needs to be opened at a traditional bank or e-money institution or payment service provider operating officially in the EEA and approved by the Estonian Financial Supervision and Resolution Authority (FSA). We have created a list of different FinTechs’ where you will find over 20 crypto-friendly banking options.

Taxation

Taxation of crypto company in Estonia

There’s no specific tax regime for crypto companies in Estonia. Estonian company taxation system has been on the number one position for 4 years in a row on the OECD tax competitiveness index. Estonian companies have no corporate tax. Tax is only paid when profit is distributed. Profit can be distributed by paying dividends (20% tax on gross dividends) or through paying salaries (taxed in the country of residency of the recipient). Crypto exchange is considered as non-taxable revenue with respect to VAT, most cases there is no VAT tax on crypto.

State fee

The state fee for obtaining the license

Every license provider must pay the 10 000€ state fee for the submission of license application. Also, a state fee of 4,000€ shall be paid for the review of an application for the amendment of an activity license in the field of virtual currency. No state fee shall be charged for the review of an application for change if the change is limited to the change of the address data of the location of the company within Estonia.

Our Experience

Our experience and expertise

Comistar has helped more than 60 companies to obtain the Estonian cryptocurrency licenses, including for clients outside of Europe (China, South- Korea, Japan, Australia, India, Canada, and Russia). We have given talks, written books and developed applications for the crypto and tokenization industry and have been active in the crypto space for several years. Comistar provides accounting for crypto companies, legal & tax advisory, as well as tech expertise via our partners. Read our article about new license requirements.

Our services

  • Assistance with share capital increase
  • Recruitment services (AML officer, auditor, management board member)
  • Finding a suitable office space
  • Drafting the AML Rules of Procedure (EST-ENG)
  • Risk Assessment and Risk Appetite Statement
  • PoA for submitting the license application to FIU
  • Assisting with providing all the necessary documents and consulting with the FIU
  • Assistance with opening bank accounts
  • Obtaining the balance sheet
  • Drafting the Privacy Policy
  • Cookie Policy
  • Terms and Conditions

Our partners

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