On November 19, the Estonian Financial Intelligence Unit (FIU) issued a precept on the provision of data in accordance with § 58 of the Money Laundering and Terrorist Financing Prevention Act. The request was addressed to companies that received a license for the exchange of virtual values or a license for a wallet of virtual values.
According to this precept, it is necessary to fill out an online questionary (35 or 28 questions depending on the type of license) and attach an excel file (Appendix No.2) with customer information for 2018-2019. If the company has licenses both for exchanging virtual currency and for a virtual currency wallet, questionary and excel files are submitted separately for each type of activity. Failure to provide information is a violation of the Act and entails a fine of between 1,000 and 4,000 euros.
Questionary is to be filled in Estonian and all fields are required. It is mentioned, that according to the technical features, there is no way to save an half-filled form and then continue editing. Therefore, it is recommended to prepare answers to all questions according to Appendix No.3 and then fill out and submit the questionary simultaneously. The last date to submit information is December 19th of 2019.
If the company has not yet started the activity for which the license was obtained, then instead of the questionnary and the excel file, a written confirmation signed by the company representative containing information about the lack of activity, contact details and license numbers is submitted.
Please note, that if more than 6 months have passed since the receipt of the license until the confirmation of the absence of activity, then in accordance with § 75 of the Law, the FIU has the right to terminate such a license unconditionally.
Our company specialists will provide support in filling out the questionnaire correctly (in accordance with the requirements of the FIU), translating into Estonian, and other related issues.