Selgitustaotlus

Financial Intelligence Unit e-mail: [email protected] 19.05.2021 REQUEST Whereas the definition of "currency exchange service" is not clearly explained within the regulation by Money Laundering and Terrorist Financing Prevention Act, please clarify § 25 of the "Money Laundering and Terrorist Financing Prevention Act" of Estonia and ask the following questions: 1. Does condition 1(2) "The currency exchange service may be provided without identifying the person participating in the transaction of the value of the amount exchanged in cash in a one-off transaction or linked transactions do not exceed 1,000 euros "stipulated under Article "§ 25" applies also to the virtual currency service provider? 2. If yes, does this condition where the "value of the amount exchanged in cash in a one-off transaction or linked transactions" apart from mentioned cash also applicable to fiat and electronic transactions? 3. In our understanding, paragraph 1(2) of Article § 25 is related to the "virtual currency service provider" that provides virtual currency exchange services and allows the "virtual currency service provider" not identifying the person participating in the transaction of the value of the amount exchanged in cash in a one-off transaction or linked transactions does not exceed 1,000 euros if the transaction also has been done electronically/remotely. Yours Sincerely, Oksana Bibikova /digital signature/ Financial Intelligence Unit e-mail: [email protected] 19.05.2021 REQUEST Whereas the definition of "currency exchange service" is not clearly explained within the regulation by Money Laundering and Terrorist Financing Prevention Act, please clarify § 25 of the "Money Laundering and Terrorist Financing Prevention Act" of Estonia and ask the following questions: 1. Does condition 1(2) "The currency exchange service may be provided without identifying the person participating in the transaction of the value of the amount exchanged in cash in a one-off transaction or linked transactions do not exceed 1,000 euros "stipulated under Article "§ 25" applies also to the virtual currency service provider? 2. If yes, does this condition where the "value of the amount exchanged in cash in a one-off transaction or linked transactions" apart from mentioned cash also applicable to fiat and electronic transactions? 3. In our understanding, paragraph 1(2) of Article § 25 is related to the "virtual currency service provider" that provides virtual currency exchange services and allows the "virtual currency service provider" not identifying the person participating in the transaction of the value of the amount exchanged in cash in a one-off transaction or linked transactions does not exceed 1,000 euros if the transaction also has been done electronically/remotely. Yours Sincerely, Oksana Bibikova /digital signature/ Saatja: Oksana Bibikova <[email protected]> Saadetud: 19.05.2021 10:07 Adressaat: Rahapesu <[email protected]> Teema: PÄRING Manused: Графика-1.png; FIU_Reguest_19.05.2021.asice; FIU_Reguest_19.05.2021.pdf TÄHELEPANU! Tegemist on väljastpoolt asutust saabunud kirjaga. Tundmatu saatja korral palume linke ja faile mitte avada! Tere Käesolevaga edastame LensLegal OÜ-u päringu. Palume kinnitada e-kirja koos lisadokumendiga kättesaamist. Lugupidamisega, Oksana Bibikova LensLegal OÜ Tallinn, Estonia WhatsApp/Viber/Messenger: +372 56607536 www.lenslegal.ee [email protected] -------------------------------------------------------------------------------- Please note that this message may contain confidential information. If you have received this message by mistake, you are requested to immediately inform the sender by sending a reply and to delete the message from your system without distributing or retaining any copies of it. Any action against this may be punished under statutory law. We assume no responsibility for any loss or damage arising from the receipt or use of this e-mail as the receiver opens it at his or her own risk.