Saatja: "rahapesu - RAB" <
[email protected]>
Saaja: "'Lilita Knapsa'" <
[email protected]>
Teema: RE: AML officer
Kuupäev: 2025-12-15 12:06
Dear Lilita Knapsa
Currently it is permitted for gambling operators to have their compliance
officers outside of Estonia. Please note, however, this may be subject to
change in the near future if new legislation regarding gambling operators
comes into force. Once that happens, gambling operators must comply with the
new regulations within an allocated timeframe, including the requirements
for compliance officers as they are stated in § 17 of the Money Laundering
and Terrorist Prevention Act. According to the law, only a person who works
permanently in Estonia may be appointed as a compliance officer.
Kind regards,
Rahapesu Andmebüroo | Estonian Financial Intelligence Unit
Tel +372 696 0500 | Pronksi 12, Tallinn | <https://www.fiu.ee/> www.fiu.ee
From: Lilita Knapsa <
[email protected]>
Sent: Thursday, November 20, 2025 8:38 AM
To: rahapesu - RAB <
[email protected]>
Subject: Re: AML officer
Dear Rahapesu,
Thank you for your answer. Just to be sure, It means that we can hire an AML
(Compliance) officer in Latvia, and the officer will be located in our
Latvian office?
And in case of a change in the Act in future we still can keep an AML
officer in the Latvia office?
Regards,
Lilita Knapsa
On Fri, Nov 7, 2025 at 1:49 PM rahapesu - RAB <
[email protected]
<mailto:
[email protected]> > wrote:
Dear Lilita Knapsa,
Thank you for contacting the Financial Intelligence Unit of Estonia (FIU).
In your 24.10.2025 letter you requested information regarding the
requirements for an AML officer and information for AML requirements in
English.
Requirements for AML compliance, including requirements for the AML officer
(also referred to as a compliance officer), are regulated in the Money
Laundering and Terrorist Financing Prevention Act (hereinafter the Act,
found here:
https://www.riigiteataja.ee/en/eli/ee/520032025013/consolide/current).
According to § 2 (1) 3) of the Act, gambling operators, except for
organisers of commercial lotteries are considered obliged entities. The
requirements for a compliance officer are described in § 17 of the Act.
According to the act, the appointment of a compliance officer is mandatory
for obliged entities such as credit institutions, financial institutions or
obliged entities specified in subsection 1 of § 70 of the Act. However,
other obliged entities (e.g. gambling operators) are also allowed to appoint
a compliance officer. Entities not listed above do not have to meet the
strict requirements described in § 17 (5) of the act for the compliance
officer. However, it is possible that gambling operators may become subject
to licensing by the FIU in the near future which means that when appointing
a compliance officer, it would be wise to take these requirements into
consideration. Currently, only notifying us of the appointment of a
compliance officer via e-mail is sufficient.
Hopefully we have answered your questions.
Kind regards,
Rahapesu Andmebüroo | Estonian Financial Intelligence Unit
Tel +372 696 0500 | Pronksi 12, Tallinn | <https://www.fiu.ee/> www.fiu.ee
From: Lilita Knapsa <
[email protected] <mailto:
[email protected]> >
Sent: Friday, October 24, 2025 8:12 AM
To: rahapesu - RAB <
[email protected] <mailto:
[email protected]> >
Subject: AML officer
Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.
Dear Sir/Madam,
I'm writing regarding AML in upcoming online casino licenced in Estonia, we
are looking information regarding AML officer in casino site, main question
is regarding is there need to be person with specific education, or only
experience is needed? And where can I find information in English regarding
AML procedures in Estonia - reporting, documents, etc.?
It will be really helpful if you can share all that we need to know
regarding AML in Estonia.
Regards,
--
Lilita Knapsa
+371 28683184
Luckybet.ee