Estonia to introduce new and stricter law for Virtual Asset Service Providers



Estonia will be one of the first countries in Europe to regulate Virtual Assets Service Providers (VASPs) and comply with FATF Travel Rule requirement. The amended Estonian Money Laundering and Terrorist Financing Prevention Act (MLTFP Act) is currently in the consultation phase and the aim is to target all VASPs who are operating in Estonia (including both: crypto exchanges and wallets). When the law is passed decentralized platforms, ICOs, and some other services will also fall under the VASP category.


The amendments introduce for example:

  • the FATF Travel Rule, provide stricter license requirements and expand the scope of the MLTFP Act to cover new virtual currency services;

  • license application requirements are subject to change;

  • updated requirements for the management board (for example 2 years of experience + higher education obligation);

  • clearer basis for license refusal and license revocation;

  • 1st of April 2022 FIU supervision fee 1% of share capital and 0.035% of the total amount of initiated and accepted transactions;

  • 10 000 EUR is the new VASP license submission state fee;

  • 125 000 EUR or 350 000 EUR is the share capital (from 12 000 from now), depending on the activity.

Deadlines: The amended law is it is scheduled to take effect on February 1st, 2022, but before that, it needs to pass the legislative process (readings in the parliament and announcement by the president). March 18th, 2022, is the deadline for regulated crypto businesses to bring their operation and documents into compliance (within 6 weeks). All VASPS are required to submit an audit report by August 15th, 2022


From November the plan is to move supervisory from FIU to FSA

Non-compliance with the MLTFP Act can lead to the revocation of the license.

Amended Estonian Money Laundering and Terrorist Financing Prevention Act can be found here (unfortunately only in Estonian).