Estonian FIU licence: financial institutions, trust and company services, pawnbroking, precious metals

Some businesses in Estonia may start only after the Financial Intelligence Unit has granted them an activity licence under the anti-money-laundering act. This page explains which activities need it, what the applicant must have and file, the state fee and the authority's time limit.

Information as of 11 November 2026. Every numbered statement of this page was checked in the official text named below and re-checked by a second reviewer on 2026-11-11. The page is general information, not legal advice; the authority decides on every application.

What the activity is

The Money Laundering and Terrorist Financing Prevention Act (rahapesu ja terrorismi rahastamise tõkestamise seadus, "RahaPTS") requires an activity licence for four activities: operating as a financial institution; providing trust and company services; providing pawnbroking services; and buying-in or wholesale of precious metals, precious metal articles or precious stones, except those used for production, science or medicine¹.

• Financial institution. The act's list includes, among others, currency exchange providers and "other financial institutions" within the meaning of the Credit Institutions Act²: companies that are not credit institutions but whose main and permanent activity is acquiring holdings or transactions such as lending (including factoring), leasing, or guarantee and surety transactions³.
• Trust and company service provider (TCSP). A person who provides a third party, in its economic or professional activity, with at least one of: forming a company or other legal person; acting as, or arranging for another to act as, a management board member; providing a registered office, business, contact or mail address; acting as, or arranging for another to act as, a trustee or representative of an arrangement without legal personality; acting as, or arranging for another to act as, a nominee shareholder (except for companies listed on a regulated market)⁴.
• Pawnbroking and precious metals/stones. Both are obliged entities under the act⁵.

Virtual currency services are no longer on the list. Item 4 of the list was repealed from 1 July 2026 by the Crypto-Asset Market Act (krüptovaraturu seadus)⁶. No new FIU virtual currency licence could be applied for from 30 December 2024, and an existing one expired when its holder received a crypto-asset service provider licence under Regulation (EU) 2023/1114 (MiCA) from the Financial Supervision Authority, or on 1 July 2026 at the latest⁷. Licences for crypto-asset market participants are now granted by the Financial Supervision Authority⁸.

The legal act and the authority

• Act: RahaPTS, Chapter 8 (§§ 70–75¹), with the General Part of the Economic Activities Code Act (majandustegevuse seadustiku üldosa seadus, "MSÜS") for the general licensing procedure.
• Authority: the Financial Intelligence Unit (Rahapesu Andmebüroo, "FIU") grants or refuses the licence⁹ and supervises obliged entities unless the act assigns supervision to another authority¹⁰.
• Register: the Register of Economic Activities (majandustegevuse register), controlled by the Consumer Protection and Technical Regulatory Authority (TTJA)¹¹. Applications and notices are filed only through the Estonian state portal (eesti.ee) or a notary¹².

Who must apply

Every undertaking carrying on one of the four activities¹. The act exempts: a holder of a Financial Supervision Authority licence; a person required by another act to apply for one; a person holding a licence of a financial supervisor of another European Economic Area state, where the Financial Supervision Authority has been notified of the activity; and a person providing these services only within its group¹³.

Requirements for the applicant

Reliability and reputation. The licence is granted if the undertaking, its management board members, procurator, beneficial owner and owner have no valid conviction for an offence against the state, a money-laundering offence or another intentional crime, and have an impeccable business reputation; if the contact person meets the act's requirements; and, where the licence is to cover a subsidiary, if the subsidiary meets the same conditions¹⁴. Reputation is not impeccable, among other cases, where the person caused a supervised entity's bankruptcy or licence revocation, is under a business ban, or gave the FIU false information¹⁵.

Capital and seat. Sections 72¹–72⁶ of the act, which set share capital and other rules for virtual currency service providers, are repealed¹⁶. Whether capital requirements apply is specified for the client's situation. The act lists extra data for applicants not registered in the Estonian commercial register¹⁷.

Contact person (compliance officer). The management board of a financial institution and of every holder of a § 70 licence appoints a contact person of the FIU, who reports directly to the board¹⁸. Only a person who works permanently in Estonia and has the necessary education, professional suitability, abilities, personal qualities, experience and an impeccable reputation may be appointed; the appointment is coordinated with the FIU¹⁹. A board with more than one member designates one member responsible for applying the act²⁰.

AML/CFT framework (AML/CFT: anti-money laundering and countering the financing of terrorism):

• a documented risk assessment covering at least customer, geographic, product/service/transaction and channel risks²¹;
• procedures and internal control rules established by senior management, covering at least customer due diligence (simplified and enhanced), customer risk profiling, suspicions and reporting to the FIU, record keeping, identifying politically exposed and sanctioned persons and high-risk countries, and risks of new technologies and channels²²;
• training for employees who establish business relationships or make transactions, at the start and regularly²³.

Documents filed with the application

Besides the general data under MSÜS (such as name, registry code, contact details and field of activity)²⁴, the application contains²⁵:

• Place of business: each service address, including the website, and the responsible person at each.
• Ownership and management: for applicants not in the Estonian commercial register, owner, beneficial owner, management body and procurator data.
• AML/CFT and sanctions: the procedures and internal control rules; where applicable, the International Sanctions Act procedures; data of the contact person and of the person responsible for international financial sanctions.
• Criminal records and identity: where the undertaking or a management body member, procurator, beneficial owner or owner is foreign, a home-country criminal record certificate no older than three months, notarised and legalised or apostilled unless a treaty provides otherwise, and copies of identity documents for each country of citizenship. Where the certificate is insufficient, the person's sworn statement is added²⁶.
• Fitness: for each management body member and procurator, education and a full list of positions, for board members also the area of responsibility, and any documents proving reliability and reputation.
• Accounts: the undertaking's payment accounts, with identifier and account holder.
• Financial institutions only: which financial service will be provided²⁷.
• Subsidiaries: the same data for any subsidiary the licence is to cover²⁸.

State fee and processing time

State fee (State Fees Act, riigilõivuseadus, § 269(1)): EUR 345 for trust and company services, pawnbroking, and buying-in or wholesale of precious metals, articles or stones; EUR 3,300 for operating as a financial institution²⁹. It is paid when the application is filed³⁰.

Processing time. The FIU grants or refuses the licence within 60 days, counted from the submission of all compliant documents and data; it may extend the period up to 120 days, and a late decision does not mean the licence is deemed granted³¹. An application with missing, incorrect, misleading or improperly formalised data or documents is left unexamined³². The authority may ask for additional data and set a reasonable time limit for it³³. These time limits are the law's, not a promise of a licence or a date.

Revocation. Besides the general MSÜS grounds (for example knowingly false data in the application, or giving up the activity)³⁴, the FIU revokes the licence if the undertaking has received a Financial Supervision Authority licence, repeatedly fails to comply with precepts, has not started the activity within six months, or no longer meets the licence conditions and has not cured this within the term of a precept of at least 30 days³⁵.

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ prepares the application documents and manages the process. It gives no legal, audit or tax advice and cannot guarantee a licence, a date or the FIU's decision. The service rows on the licensed companies page:

• Activity licence application documentation (from €3,500): the requirements of the act for the activity, from its official text; the submission through the Register of Economic Activities and the written follow-up of the authority's questions. The state fee is separate and paid by the client.
• AML/CFT internal rules, risk assessment and procedures (from €3,200): business-wide risk assessment, internal rules and customer due diligence procedures, sanctions screening and reporting procedure, training plan. Not included: acting as compliance officer or MLRO, screening software licences, approval by any authority.
• Recruitment of an Estonia-based FIU contact person (€700, offered with the guarantee institution packages): search for a suitably qualified contact person who works permanently in Estonia and coordination of the appointment; the person's remuneration is agreed separately at market rates, and the appointment is subject to the suitability requirements.

Prices are professional fees, excluding state fees and third-party costs. Order via the request form: order form.

Sources

1. RahaPTS § 70(1) — text in force from 21.07.2026
2. RahaPTS § 6(2) p 1 and 11 — text in force from 21.07.2026
3. Krediidiasutuste seadus § 5(1) and § 6(1) p 2, 3, 6 — text in force from 01.10.2026
4. RahaPTS § 8 — text in force from 21.07.2026
5. RahaPTS § 2(1) p 6 and 14 — text in force from 21.07.2026
6. RahaPTS § 70(1) p 4; KrüTS publication RT I, 21.06.2024, 3 — text in force from 21.07.2026
7. RahaPTS § 118⁴(1), (3) — text in force from 21.07.2026
8. Krüptovaraturu seadus § 5(2) — text in force from 01.07.2024 (algtekst-terviktekst, hetkel kehtiv)
9. RahaPTS § 71(1) — text in force from 21.07.2026
10. RahaPTS § 64(1) — text in force from 21.07.2026
11. MSÜS § 8(1), (4) — text in force from 01.09.2025
12. RahaPTS § 70(6) — text in force from 21.07.2026
13. RahaPTS § 70(2) — text in force from 21.07.2026
14. RahaPTS § 72(1) p 1, 1¹, 2, 3 — text in force from 21.07.2026
15. RahaPTS § 72(2) p 1, 3, 5 — text in force from 21.07.2026
16. RahaPTS §§ 70–72; headings of the repealed §§ 72¹–72⁶ — text in force from 21.07.2026
17. RahaPTS § 70(3) p 3, 4 — text in force from 21.07.2026
18. RahaPTS § 17(2) — text in force from 21.07.2026
19. RahaPTS § 17(5) — text in force from 21.07.2026
20. RahaPTS § 17(1) — text in force from 21.07.2026
21. RahaPTS § 13(1), (4) — text in force from 21.07.2026
22. RahaPTS § 14(1), (3) — text in force from 21.07.2026
23. RahaPTS § 14(6) — text in force from 21.07.2026
24. MSÜS § 19(2) p 1 with § 15(1) — text in force from 01.09.2025
25. RahaPTS § 70(3) p 1–11 — text in force from 21.07.2026
26. RahaPTS § 70(3¹) — text in force from 21.07.2026
27. RahaPTS § 70(4) — text in force from 21.07.2026
28. RahaPTS § 70(5) — text in force from 21.07.2026
29. Riigilõivuseadus § 269(1) — text in force from 01.11.2026
30. MSÜS § 19(7) — text in force from 01.09.2025
31. RahaPTS § 71(1) — text in force from 21.07.2026
32. RahaPTS § 71(2) — text in force from 21.07.2026
33. MSÜS § 19(6) — text in force from 01.09.2025
34. MSÜS § 37(1) p 1, 2 — text in force from 01.09.2025
35. RahaPTS § 75(1) p 1–4 — text in force from 21.07.2026

Official sources

The laws this article names, each linked to its official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

• Money Laundering and Terrorist Financing Prevention Act — Riigi Teataja, English translation
• Regulation (EU) 2023/1114 — EUR-Lex
• State Fees Act — Riigi Teataja, English translation

Sources in the text are named without links; the official texts are linked under Official sources. To see which of our services your company needs, open the Business Navigator.