Karmen Turk, a sworn advocate with the TRINITI law firm, writes in an opinion piece published by ERR News that Estonia's gambling licence is failing to attract foreign operators. She does not dispute that gambling operators must combat money laundering; her complaint is that, in practice, every applicant is treated primarily as a potential risk
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A remote gambling licence is issued by the Tax and Customs Board but must first be approved by the Financial Intelligence Unit. Applicants submit internal anti-money laundering rules, appoint a contact person and provide documents on owners and managers; operators already active must meet these requirements by 1 January 2027. According to Turk, the contact person must work permanently in Estonia, the unit has indicated that one person may act for no more than two companies, and in practice internal rules are expected in Estonian.
Turk cites the unit's own figures: in 2025 only about 14 percent of reports concerned genuine suspicions, and nearly 94 percent of reports came from about a tenth of companies. She also points to a 2024 review by the Chancellor of Justice, which found that applicants are not told when their documents are complete, so they cannot know when the 60-day deadline for a decision starts.
She questions whether the location requirement fits EU law and notes that a uniform EU anti-money laundering regulation applies from 10 July 2027.
Source: ERR News, . The text above is our own summary; the words in quotation marks are the source's.
What this means for an Estonian entrepreneur
A foreign operator planning an Estonian remote gambling licence should budget time for the approval by the Financial Intelligence Unit: internal rules, an approved contact person working in Estonia and owner documents are examined before the Tax and Customs Board issues the licence. Preparing these documents completely before applying reduces the uncertainty the article describes.
We prepare the player protection and anti-money laundering documents that an Estonian gambling licence application needs. Responsible gambling procedures for an Estonian licence