AML / Compliance Officer

AML / Compliance Officer

AIF Crypto License (VASP) ICO
3 October 2022

AML officer is the contact person for the Estonian Financial Intelligence Unit (FIU), who will answer directly to the company's board. The AML officer is either employee of the company or part of the structural unit, i.e., the company board of directors. The AML officer has to notify the FIU if the company isn't following the AML regulations.

The AML officer is responsible for all reporting and communication with the Estonian FIU. Only a person who works permanently in Estonia and has the education, professional suitability, abilities, personal qualities, experience, and impeccable reputation required for the performance of the duties of a compliance officer may be appointed as an AML officer. When applying for a cryptocurrency license, an AML Officer is required for every company.

The requirements for AML officers are stated in the Estonian Money Laundering and Terrorist Financing Prevention Act (AML Act) § 17. AML officers should also be registered as company employees on the Estonian Tax and Customs Board webpage.

The appointment of the AML officer shall be coordinated with the FIU. The license application for authorization must contain the name, personal identification code (upon absence thereof, the date of birth), place of birth, citizenship, address of the location of residence, position, and contact details of the AML officer.

The AML officer, who is also a contact person of a virtual currency service provider, may not be the contact person of another virtual currency service provider or the head of a structural unit. A member of the management board of a virtual currency service provider may work as a contact person only in those virtual currency service providers where they are a member of the management board.

AML officer responsibility areas:

  1. Assuring the company's compliance with Anti Money Laundering regulations, including drafting necessary internal regulations and applications to be submitted to regulating authorities.
  2. The organization of the collection and analysis of information referring to unusual transactions or transactions or circumstances suspected of money laundering or terrorist financing, which have become evident in the company's activities.
  3. Reporting to the FIU in case of suspicion of money laundering or terrorist financing.
  4. Monitoring and implementing an ongoing AML training program for other employees.
  5. Periodic submission of written statements on compliance with the requirements arising from the AML Act to the company's management board or branch manager.
  6. Performance of other duties and obligations related to compliance with the requirements of the AML Act.

The FIU has a right to receive information from an AML officer or AML officer candidate, their employer and state databases to verify the suitability of the AML officer or AML officer candidate. Where, as a result of the check carried out by the FIU, it becomes evident that the person's reliability is under suspicion due to their past acts or omissions, the person's reputation cannot be considered impeccable, and the obliged entity may extraordinarily terminate the AML officer's employment contract due to the loss of confidence. Where the duties of an AML officer are performed by a structural unit, the provisions of this subsection are applied to each employee of the structural department.

An AML officer has a right to:

  • make proposals to the management board or branch manager of the obligated entity for amendment and modification of the rules of procedure containing AML/CFT requirements and organization of training.
  • demand that a structural unit of the obliged entity eliminate within a reasonable time deficiency identified in the implementation of the AML/CFT requirements.
  • receive data and information required for the performance of the duties of an AML officer.
  • make proposals for the organization of the process of submission of notifications of suspicious and unusual transactions.
  • receive training in the field.

Where no AML officer has been appointed, the duties of an AML officer are performed by the management board of the company, a management board member, the manager of the branch of the foreign company registered in the Estonian commercial register or a self-employed person.

In an individual case, the FIU may forward to the AML officer of the obliged entity the data registered in the FIU to the required and sufficient extent to take joint AML/CFT measures or measures for the prevention of related criminal offences.

You can find more information about our crypto license and AML/KYC-related services from the Comistar FinTech launchpad. If you're interested in obtaining our services, contact us via our webpage or write directly to You can also read about the Estonian crypto license's most recent updates from our blog.