Saatja: Vakhtang Chkhenkeli <
[email protected]>
Saaja: rahapesu - RAB
Teema: Re: Wind down of legacy Estonian VASPs
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Hello
Thanks for the answer.
Considering that there are no MiCA lcienses issued and many FIU-licensed VASPs obtained licenses in other jurisdictions or won't get any license, the questions still remains what will happened to the liabilities when the grandfathering period ends. Previously, annual report of every licensed VASP was audited and only after this submitted to the registry. Now, legacy VASPs won't be obliged to audit it and can simply upload it to the registry. Will existing liabilities (if anu) issue of individual clients or there is a mechanism in mind that will ensure that there are no active liabilities?
I understand that FIU doesn't cover prudential supervision, but is there any plan or communication to deal with the legacy VASP liabilities?
On Fri, Mar 13, 2026 at 3:58 PM rahapesu - RAB <
[email protected]<mailto:
[email protected]>> wrote:
Dear Vakhtang Chkhenkeli,
Thank you for contacting Estonian Financial Intelligence Unit (EFIU). You have sent inquiry about Estonian virtual asset service providers (VASPs) and their licenses.
According to the Estonian Money Laundering and Terrorist Financing Prevention Act (MLTFPA) § 1184 subsection 3 the virtual currency service provider’s authorisation issued under this Act is deprived of effect under clause 1 of subsection 1 of § 75 of this Act where the undertaking has been issued, by the Estonian Financial Supervision and Resolution Authority, a crypto-asset service provider’s authorisation under Regulation (EU) 2023/1114 of the European Parliament and of the Council or, at the latest, on 1 July 2026.
So VASPs who have active license from EFIU at the moment must apply for Mica license or starting from July 1st 2026 they are not allowed to offer virtual asset services anymore. If a company proovides services after the license is expired, it’s an unauthorized activity and is punishable the law. MLTFPA or Market in Crypto-Assets Act doesn’t specify conditions of terminating business. Every licensed company has to keep data and documents according to the MLTFPA § 47, even if the license has expired.
The EFIU does checks and procedures according to Money Laundering and Terrorist Financing Prevention Act and starts supervisory activity if applicable. Supervisory activities cover the area of anti-money laundering, not full prudential supervision or consumer protection.
Kind regards,
[cid:ii_19ce7bf9e374cff311]
Rahapesu Andmebüroo | Estonian Financial Intelligence Unit
Tel +372 696 0500 | Pronksi 12, Tallinn | www.fiu.ee<https://www.fiu.ee/>
From: Vakhtang Chkhenkeli <
[email protected]<mailto:
[email protected]>>
Sent: Thursday, March 12, 2026 3:05 PM
To: rahapesu - RAB <
[email protected]<mailto:
[email protected]>>
Subject: Wind down of legacy Estonian VASPs
Hello
I'm writing about widing down of legacy Estonian VASPS whose licenses were issued by FIU. Is there any agreement or procedure agreed with the Estonian FI to manage the process? The ESMA guidelicnes or Küptorahaturuseadus doesn't provide any details.
How will you make sure that legacy VASPs don't have client liabilities or all other liabilities were cleaned? Will you request the audit?
I sent the similar question to the FI, but I haven't received the answer yet.
Thank you