Table of contents:
- PART I: The Past and Present State of FinTech and Cryptocurrency Exchange Licencing in Europe and Estonia
- A balanced regulatory system for crypto-assets is needed in order to support innovation
- Establishing your licenced cryptocurrency exchange in Estonia in 2020
- Determining the registered office, place of business, management and compliance officer locations under the MLTFPA
- Character and suitability requirements for Estonian crypto-asset and cryptocurrency licence applicants’ management board members
- Designating an AML compliance officer
- Choosing a bank for the operation of a cryptocurrency exchange or custodial wallet service in Estonia
- Applying for and obtaining a bank account as a cryptocurrency exchange or cryptocurrency wallet service
- PART II: Obtaining a Cryptocurrency Exchange Licence in Estonia: Step by Step Guide
- In Conclusion
Part I: The Past and Present State of FinTech and Cryptocurrency Exchange Licencing in Europe and Estonia
In the last decade, the way in which assets are developed and managed has undergone significant change. New classes of assets have given rise to an entirely new, technology-driven finance industry: FinTech. FinTech businesses use innovative technologies to automate and increase the availability of financial services. Leading the charge into a future of digitized assets are blockchain technologies and the companies that manage them (e.g cryptocurrency exchange). These organizations develop, manage, and process transactions involving crypto-assets, the most well-known of which are cryptocurrencies.
The pace of FinTech development has been rapid. From the introduction of Bitcoin, the first cryptocurrency in 2009, the industry has grown to represent a range of blockchain-verified assets. These assets vary in their characteristics with some being used as a medium of exchange similar to other currencies while others resembled securities. Thousands upon thousands of different cryptocurrencies and tokens now exist to serve the needs of businesses and investors.
Not everyone understands blockchain technology or its potential uses in the financial realm. In particular, conventional financial institutions have been slow to adopt crypto-related services. Banks and stock exchanges around the world continue to focus their attention on the management and transfer of traditional assets including stocks, bonds, gold, and other tangible goods. Governments, too, have struggled to adapt to the new face of finance. Reactions among state agencies have varied. Some governments have even banned the use of cryptocurrencies and other blockchain-backed assets.
Nonetheless, the market capitalization for crypto-assets has grown exponentially. The FinTech industry has now reached a point where it can no longer be ignored. Moving beyond the exclusive domain of innovative startups, cryptocurrencies and crypto-assets are poised to enter the mainstream. As institutional investors pour funds into the crypto marketplace, the market volume of crypto-assets will continue its surge. And the need to regulate and licence FinTech assets and investment vehicles will as well.
Further, the rising popularity of crypto-assets means that there will be plenty of innovative entrepreneurs looking for ways to make money in this field. Some will mine bitcoins, some will conduct ICO’s, some will invest in crypto-assets while others will trade with them or establish platforms that can be used for trading – cryptocurrency exchange platforms. But as is the case with any sector or industry facing stiff competition – nothing is as easy as it seems. Cryptocurrency mining is getting more expensive and complicated by the day, while trading with crypto-assets is a high-risk business due to the volatile nature of these assets.
For these reasons and more, FinTech’s users will look to their governments and regulatory bodies within the finance industry to ensure that they can conduct cryptocurrency transactions with the same security and ease as they do when using traditional assets. That is one reason cryptocurrency exchanges are in the spotlight right now. Cryptocurrency exchange platforms are the portals to the crypto ecosystem that give the general public access to crypto-assets so they can easily invest in them and trade with them.
The country of Estonia has been a leading voice in the development of a favorable environment for crypto-assets and the licencing of cryptocurrency exchanges. In the following sections, we will first take a look at the European and, specifically, Estonia’s regulatory climate for cryptocurrency exchanges before turning our attention to the steps your organization must follow to secure your Estonian cryptocurrency exchange licence.
A balanced regulatory system for crypto-assets is needed in order to support innovation
Maintaining efficient and secure cryptocurrency exchanges requires the adoption of modern regulatory structures designed to handle these new digital assets. Leading banks and other stakeholders of the FinTech sector agree that regulatory oversight of cryptocurrency markets is inescapable. The question that remains is how to craft these new regulations so that they afford industry players clear and fair protections while not hindering innovation or economic growth.
The current legal and political landscape surrounding cryptocurrencies varies from state to state and region to region. In Europe, regulations are developing to legitimize and ensure the future of digital finance. These regulations will make the crypto environment more attractive for new businesses, banks, and investors as well as facilitate business activities in this newly forming ecosystem. Within the European Union, each state has its own regulations regarding cryptocurrencies and cryptocurrency exchanges. Each state’s regulations are honored across the trade bloc.
The European Union’s AML rules apply to cryptocurrency exchanges
On January 10, 2020, the European Union’s fifth anti-money laundering (AML) directive called “5AMLD” went into effect.
The 5AMLD defines cryptocurrency as:
“A digital representation of value that is not issued or guaranteed by a central bank or a public authority, is not necessarily attached to a legally established currency and does not possess a legal status of currency or money, but is accepted by natural or legal persons as a means of exchange and which can be transferred, stored and traded electronically.”5AMLD
Under the directive, crypto-asset managers are defined as “obligated persons” and they are subject to the same regulatory requirements as other financial institutions.
In accordance with 5AMLD, cryptocurrency exchanges must develop and implement “Know Your Client” (KYC) procedures. They are also required to file reports about any suspicious activities and constantly monitor ongoing transactions.
Despite having rules which ease entry into the FinTech industry, Estonia was and is a country where cryptocurrencies and cryptocurrency exchanges are regulated with sufficient depth to meet the requirements of the EU’s 5AMLD.
Estonia’s regulatory stance toward cryptocurrencies and exchanges has fueled the filing of a wave of applications for cryptocurrency exchange licences
Estonia’s Money Laundering and Terrorist Financing Prevention Act (hereinafter MLTFPA) governs financial service providers in the state, including FinTech providers. Except for those areas of activity covered by the Financial Supervision Authority, relevant financial services activity licences are issued by the Estonian Financial Intelligence Unit (FIU). Estonia’s FinTech rules were (and are) among the most open and lenient within Europe and are comparable to those of Malta and Switzerland. This fact began to draw the attention of crypto enthusiasts from around the world in 2018.
In 2017 Estonia’s FIU received just 108 applications for financial services licences. In 2018, nearly 1,200 licence applications were received. Of these applications, 629 were applications for activity licences that would permit the exchange of cryptocurrencies for fiat money or licencing to use cryptocurrencies as a method of payment and 533 were for cryptocurrency wallet services.
But Estonia’s early regulations had weaknesses. Often organizations that did not intend to offer financial services in Estonia would apply for a licence in order to offer services in other EU nations. During this period, the regulation’s definition of “operating” in Estonia was not clear. Organizations might seek a licence for their cryptocurrency exchange in Estonia despite having no physical presence there. It was impossible for the Estonian government to exercise supervision over these companies because neither the technical platform providing the service nor the employees implementing the anti-money laundering requirements of the MLTFPA were located in Estonia.
Along with a growth of ICO-related frauds, other issues of trustworthiness arose as a result of these cracks in Estonia’s regulatory wall. In some cases, recipients of cryptocurrency licences would offer other services for which they were not properly licenced.
In October of 2018, the Financial Action Task Force (FATF) met to address these shortcomings and approved recommendations to improve the supervision of cryptocurrency-related service providers. Estonia’s finance laws were subsequently amended to strengthen the FIU’s oversight and authority with regard to the granting of crypto-related licences.
The law imposed additional requirements for businesses seeking activity licences as financial service providers, financial institutions, and cryptocurrency service providers. Those seeking cryptocurrency exchange or other crypto-service licences in Estonia are now subject to the same rules that applied to traditional financial institutions. In particular, the new law requires FinTech providers to maintain a physical presence in Estonia to enable regulatory supervision.
The amendments to the MLTFPA took effect March 1, 2020 and all companies with existing licences must bring their operations into compliance by July 1, 2020. Estonia’s new regulatory guidelines enable businesses to pursue their plans while ensuring that the EU’s anti-money laundering rules are met. This brings safety and security to all stakeholders in the FinTech industry.
Establishing your licenced cryptocurrency exchange in Estonia in 2020
Estonia’s MLTFPA now requires that all cryptocurrency exchange licence applicants have a physical office located in Estonia. The organization must also appoint a management board member (otherwise known as a director) who is responsible for implementing the requirements to comply with the MLTFPA. The organization must have local board members and their anti-money laundering compliance appointee (AML compliance officer) must be present in the state. These rules were developed to enable the FIU to better execute its duties and prevent money laundering.
The general principle that applies to financial service businesses is that the place of business and registered location of an entrepreneur in the financial sector must be in the same state. Expanding a similar requirement to entrepreneurs whose area of activity is the provision of the service of a cryptocurrency exchange for money, or cryptocurrency wallet service reduces the possibilities of Estonian companies being abused for criminal purposes.
Further, the FIU can exercise supervision over the company only if the company’s place of business is in Estonia. Setting down this requirement was also necessitated by the need to implement the national supervision measures more effectively. The FIU must be able to quickly get in touch with the AML compliance officer for the prevention of money laundering and to ensure faster access to data. This is the reason the licenced entity’s AML compliance officer must be located in Estonia.
Licenced companies must also maintain a complete and up-to-date overview of all customers and operations in compliance with AML and KYC rules. The FIU is authorized to ask questions about the activities of the company especially regarding compliance with predefined anti-money laundering and know your client policies. Also, the FIU is authorized to visit the local office of the company in Estonia, monitor its work processes, and conduct interviews with staff.
Determining the registered office, place of business, management and compliance officer locations under the MLTFPA
According to the new rules, the registered location, management board’s location, and place of business of a company applying for a licence from the FIU must be in Estonia. The method for establishing proof of location varies, depending on the person or entity involved. In general, the following rules apply:
Registered business location – The registered location of the organization is defined by its formation agreement, such as its partnership agreement, or in its articles of association. The determination of the location is a mandatory requirement upon the founding of any legal entity governed by private law. For foreign companies, compliance with the MLTFPA means that they will need to establish a registered branch office in Estonia.
Location of place of business – While they may be found in the same location, a company’s place of business and its registered office do not have to be co-located. The place of business is not determined legally but factually–it is the place where the organization’s business activities take place. The place of business is the place where the main managerial and control functions pursuant to money laundering legislation are performed and where the financial service is provided.
Residence and workplace of the member of the management board and AML compliance officer – In addition to maintaining a physical presence and registered location in Estonia, at least one member of a licenced entity’s management board and its AML compliance officer must be located in Estonia. To meet this standard, each individual must be an Estonia tax resident as defined by the Estonian Income Tax Act. This act requires that the individual reside in Estonia for a minimum of 183 days within a twelve month period or have a place of residence registered in the Estonian Population register.
Character and suitability requirements for Estonian crypto-asset and cryptocurrency licence applicants’ management board members
When applying for an activity licence in Estonia, a business must demonstrate the trustworthiness of the current or proposed members of its management board and present proof that they are suitable candidates for providing the public with services that require heightened trustworthiness and care. Each manager included in the application must submit sufficient data to demonstrate that they have the knowledge, skills, experience, education, professional suitability, and impeccable business reputation required to provide financial services. Normally, such information is included in the individuals’ CVs, which should accompany the activity licence application.
The following standards are used to assess an individual’s character and suitability for financial activity licencing in Estonia:
Education, knowledge, skills, and experience, and professional suitability – The person must have sufficient knowledge, skills, and experience to perform their obligations with the quality characteristic to their position. When assessing the individual’s knowledge, skills and experience, it is crucial to evaluate how the person’s education, received training, and previous work experience support or are otherwise related to the professional tasks and the requirements necessary for working there.
When assessing the skills and experience, the person’s previous positions, work experience, work character and scope of area of responsibility and influence, areas of responsibility, number of subordinates, nature of performed tasks, relevance of the acquired experience in the specific case, and other factors will be considered. The aforementioned is assessed against the responsibilities of the position and the activities of the specific supervision subject. The person’s level of education must support the obligations accompanying their position, allow them to understand the risks involved in the responsibility related to their position, and, thus, also bear the related responsibility.
Unless a higher level of education is required by law, managers must have at least a secondary education. If the person lacks the required education, sufficient professional knowledge, skills, or relevant experience then they are unsuitable to serve as a member of the management board of a traditional or crypto-related financial institution.
An impeccable business reputation – An “impeccable business reputation” is an undetermined legal term, which the supervisory agency assesses in each occasion in the light of the specific matters, considering all the circumstances with the aim of protecting the general trustworthiness of the financial sector both in its functioning and in the eyes of the public. The agency will consider factors with the purpose of preventing the financial sector from being used for money laundering or terrorist financing.
Each person is presumed to have the requisite impeccable business reputation unless proven otherwise. A person’s reputation, for these purposes, is formed by both earlier and present activities and inactivity. When evaluating an entity’s application for licencing, the FIU may evaluate the reputations of the managerial body members and shareholders, legal representatives, and any persons who have significant influence over the management of the organization.
Designating an AML compliance officer
Section 17 of the MLTFPA regulates the appointment of the responsible management board member and FIU contact person, more commonly referred to as the AML compliance officer. Although it is not an obligation pursuant to FATF recommendations or the European Union directives, the appointment of a contact person significantly contributes to the effectiveness of anti-money laundering and terrorist financing prevention efforts according to both supervisory agencies and obligated persons.
Subsection 17 (1) of the MLTFPA clarifies that if there is more than one member of the board, the company must appoint a single member of the board who shall be responsible for the implementation of the legislative acts and instructions provided in the law and pursuant to law.
The manager appointed as the AML compliance officer must have the knowledge, skills, experience, education, professional suitability, and impeccable business reputation required for providing the proposed financial services. Thus satisfaction of the respective requirements is also a prerequisite for obtaining an activity licence.
What prompted this amendment to the MLTFPA? Although under an activity licence issued in Estonia, an Estonian company can provide its services via internet across the world, the Estonian supervisory agencies are the ones who verify whether the companies providing services with activity licences issued in Estonia meet the mandatory requirements provided in the MLTFPA and legislation drawn up pursuant to it.
Prior to the 2020 amendment of the MLTFPA which requires the AML compliance officer to reside in Estonia, communication between a company was not sufficiently secure and timely to allow the FIU to quickly address suspicious activities. With the organization’s AML compliance officer situated in Estonia, the FIU and that officer will be able to communicate without delay during urgent situations. The FIU will also be able to more quickly obtain needed documents and act to prevent the disposal and use of assets, which is extremely important in matters related to terrorist financing.
When verifying that the appointed AML compliance officer works in Estonia, the FIU may consider, among other things,
- whether the person has a legal basis for permanently staying in Estonia
- whether they are registered in the register of employees
- whether they receive a monthly remuneration that corresponds to the position
Most entities sign agreements which authorize their AML officer residing in Estonia to act on behalf of the organization with regard to compliance and other business functions. These agreements help to demonstrate the officer’s qualification for the role.
Choosing a bank for the operation of a cryptocurrency exchange or custodial wallet service in Estonia
The new amendments to the MLTFPA require that licenced services have at least one payment account with a bank or service provider established within the European Economic Area (EEA) to pay in the share capital of the company. But, cryptocurrency exchanges and custodial wallet service providers are classified as high risk clients by most traditional financial institutions. This treatment has made opening a bank or payment account one of the biggest hurdles to establishing an operating cryptocurrency exchange in Estonia.
It is important to note that the companies are not required to have an account in a brick and mortar bank, but can also use the services of licenced payment service providers or E-money institutions (commonly referred to as EMIs). These organizations provide an alternative to the traditional banks which often reject crypto-industry clients. EMIs are not permitted to offer the financial services such as loans or leases that are typically associated with traditional credit institutions. However, in addition to payment services, many EMIs also provide online payment, card acquiring and KYC services that are not part of the service portfolio of most banks.
Because opening an EMI account can often be completed without visiting a physical office, entrepreneurs active in the cryptocurrency field may find that an EMI is the more convenient choice when selecting a payment account provider. Of course, there is no guarantee that this remote account opening option will be available.
The main factors a FinTech service provider should consider when deciding where to open a banking account are:
- The structure of the company and citizenships of the ultimate beneficial owners
- The countries of operations
- The services offered by the company
- Whether the company intends to or has carried out an ICO or STO
Regardless of the type of institution chosen, banks and payment service providers are mandated by law to implement enhanced due diligence measures when servicing cryptocurrency exchanges and wallet service providers. Thus, service fees will be considerably higher than those charged to traditional businesses. However, many EMIs are willing to offer discounts on their fees based on the annual turnover and monthly trading volumes of a client company.
Applying for and obtaining a bank account as a cryptocurrency exchange or cryptocurrency wallet service
Banks that accept cryptocurrency clients prefer to service companies who already have an established business with considerable turnover and who are able to present financial documentation of their activities. Businesses that are in the development stage should be prepared to demonstrate their viability to potential banking partners.
The following documents and processes are likely to be required when an organization opens a bank account to support their application for an Estonian cryptocurrency exchange licence:
Identity verification – When opening an account with a traditional bank, applicants usually will be required to visit the bank’s offices in person to verify the identities of the persons who will have access to the bank account. On the other hand, EMIs may permit this verification to take place via the submission of digital images of each access holder or through video chat.
Proof of business concept – The most important document to the success of obtaining a bank account as a new cryptocurrency company is the company’s business plan. The business plan should be treated as an investor pitch to the bank or EMI. It should provide the reader with an overview of the structure of the company, a description of the services offered, name the target market(s), and provide an initial forecast for the first year of business. In addition, the documents should list the risk factors of the business and steps that company will take to mitigate those risks.
Business records and documentation – Additional documents and their formalization will vary among providers, but in most instances, the company will need to provide copies of incorporation documents such as its proof of registration, list of shareholders and directors, and licences.
During the account opening process, banks or service providers may also request copies of contracts or signed letters of engagements from businesses that provide services to the cryptocurrency exchange.
Individual members and managers documentation – Persons included in the structure of the company, such as the ultimate beneficial owners ( UBOs), directors, and the AML compliance officer, will be required to submit copies of their passports to verify their identity as well as present proof of residency documentation (e.g. a utility bill). In most cases, all documents and passport copies must be presented in English and notarized or apostilled. The AML officer’s CV must also be submitted to show that the person has the necessary training or experience to carry out their duties.
The processing time of the application will vary and is mostly dependent on the complexity of the business model. Most banks and EMIs are able to provide initial feedback about an entity’s application within 10 days of receiving the required documents.
PART II: Obtaining a Cryptocurrency Exchange Licence in Estonia: Step by Step Guide
There are several steps that a crypto entrepreneur or business should take once they have decided to apply for an activity licence to operate a cryptocurrency exchange or cryptocurrency wallet service in Estonia. To expedite this process, many crypto organizations find it beneficial to partner with a consultant who can guide and assist them through this process.
Company formation and share capital contribution to the deposit account
The first step is to choose an appropriate legal form of your Estonian company. An Estonian private limited company (Osaühing or OÜ in Estonian) is the most common form of business, as its shareholders are not personally liable for the obligations of the company. There are no restrictions on the number of shareholders and board members who can be part of the private limited company.
A company seeking to incorporate in Estonia may do so quickly online using the benefits of Estonia’s unique e-Residency program. A prerequisite of online incorporation is that all the shareholders and directors have been granted e-Residency. Alternatively, an organization may use a power of attorney to appoint an individual, such as the employee of a corporate service provider, who resides in Estonia to serve as their representative in forming the company.
During the incorporation process the required share capital of 12,000 euros must be paid into the Commercial Registry deposit account. Transferring a business entity established by a non-owner representative must take place in a notary office. It can take up to 5 working days for all information to be changed and reflected online.
Registration of employment
If a licence applicant’s AML compliance officer is not a managing board member, they must be an employee of the organization. To establish the employment of the AML compliance officer, these individuals must be registered in Estonia’s employment register which is overseen by the Estonian Tax and Customs Board. Proof of employment must be established at the time that the application for an activity licence is submitted with the FIU.
The registration of employment does not have any effects on the tax residency of a director or manager or the AML compliance officer.
Renting an office space
A licenced cryptocurrency exchange must have an office located in Estonia and the company must present either proof of ownership or right of usage of the space as part of the licencing procedure.
Payment account opening
Before an application for cryptocurrency licences can be submitted, the company must have a payment account with a credit institution or payment service provider established in the EEA.
In addition, the company must demonstrate that it is funded. Registered capital of 12,000 euros must be paid as a monetary payment into the company account.
Drafting the business plan of the company
A company which is applying for the cryptocurrency exchange licence must submit a business plan to the FIU. The document must be signed by the management board member either by hand or by using an e-Residency card.
The business plan should include, at a minimum, the following information:
- A general description of the services offered (exchange, wallet etc.) and how they will be provided (e.g. web platform, mobile application)
- A general description of implementation of the due diligence measures the company will undertake
- An estimate of the time frame in which the company will begin operations after receiving its Estonian cryptocurrency exchange or crypto wallet services licence. (The company must be able to begin offering its services 6 months after the licences have been granted.)
- A list of the company’s payment accounts
Criminal certificates of each of the UBO(s), shareholder(s), member(s) of the management board, and AML compliance officer
All the persons included in the structure of the company must provide original criminal certificates from their country/countries of citizenship. This certificate must be obtained no more than 3 months prior to the submission of the licence application. Thus, best practice is to apply for the certificates after the company has opened its payment account.
If the certificates are issued by an EU member state, then it is sufficient to have the issuing authority attach the standardized multilingual form to the certificate pursuant to the EU Regulation on Public Documents (Regulation 2016/1191).
If the certificates are issued by a non-EU member state, then the document will require either apostille or legalization before they can be used for the licence application. In addition, if the certificate is not in Estonian, English or Russian, it will need to be translated by a sworn translator.
Procedural rules of the company
Pursuant to the MLTFPA, cryptocurrency exchange service providers are obligated to compile rules of procedure for performing the various duties specified in the MLTFPA for their economic activities that allow for effective mitigation and management of, inter alia, risks relating to money laundering and terrorist financing.
The service provider must establish internal control rules that describe the internal control system including the procedure for the implementation of internal audit and, where necessary, compliance control, which sets out, inter alia, the procedure for employee screening. If the company is under no obligation to implement internal audit then this should be mentioned in the internal control rules.
The rules of procedure and internal audit rules consist of:
- Code of Conduct for the application of customer due diligence measures
This is to ensure the proper identification and verification of customers or persons participating in transactions, as well as ongoing monitoring of business relationships, including transactions carried out during business relationships, regular verification of data used for identification, update of relevant documents, data or information and, when necessary, identification of the source and origin of funds used in transactions.
- Code of Conduct for the collection and preservation of data
This section stipulates requirements for the preservation of data and documents used for identification.
- Code of Conduct for the performance of the notification obligation and for informing the management
This section stipulates the rules and procedures in case suspicious activities have been noticed by the service provider.
- Internal Control Rules
Internal rules are for the company’s structure and point out the tasks and requirements for the persons that are responsible for the supervision of the activities.
Applying for the licence
Once all the necessary documents have been drafted and gathered, the cryptocurrency services licence application is submitted through the Estonian Registry of Economic Activities. The application will be processed by the FIU within 60 days. However, this period may be extended to 120 days if any additional documents and/or information are requested by the FIU. During its evaluation, the FIU may call in the AML compliance officer of the company for an interview to assess the person’s suitability to carry out the obligations of the officer.
Once granted, all the organization’s licences are publicly available in the Estonian Registry of Economic Activities. There are no separate certificates issued to the licenced company. A digital copy of the licence may be obtained from the Registry.
The company is obligated to start providing its services within 6 months of receiving the licence.
Through our extensive experience in working with cryptocurrency exchanges and custodial wallet service providers in Estonia, we have formed several partnerships with banks, EMIs and service providers enabling us to assist cryptocurrency companies in opening payment accounts for their business.
Our experienced team of advisors takes the time to familiarise themselves with the operations and needs of each organization before making recommendations for suitable payment services and other providers.
In addition, we will assist you in gathering and formalizing all the required documents for opening an account and completing the cryptocurrency licence application process. In most cases, our team is able to handle the entire process up until the signing of the agreement and issuing of the licence. We will be at your full disposal at the duration of the process.
The following summary details the most important steps of the entire process and identify those steps that Incorporate in Estonia can help you complete:
|1||Submission of the e-Residency application||Incorporate in Estonia|
|2||Drafting the incorporation documents||Incorporate in Estonia|
|3||Share capital payment to Commercial Registry’s deposit account||Client|
|4||Submission of the incorporation documents||Incorporate in Estonia|
|5||Registration of employment of director and AML Compliance Officer||Incorporate in Estonia|
|6||Find suitable office space||Incorporate in Estonia|
|7||Conclude the rental agreement||Director of the company|
|8||Payment account opening||Client/Incorporate in Estonia|
|9||Transfer of share capital to the company’s account||Client|
|10||Conclude the accounting agreement||Client/Incorporate in Estonia|
|11||Start of salary payments to the director and AML compliance officer||Client/Incorporate in Estonia|
|12||Draft a business plan for the company||Client/Incorporate in Estonia|
|13||Draft the internal procedural rules of the company||Incorporate in Estonia|
|14||Gather the criminal certificates of the UBO(s), shareholder(s), director(s) and AML compliance officer||Incorporate in Estonia|
|15||Submission of the licence application(s)||Incorporate in Estonia|
|16||Start of activities of the company||Company|
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