Subject: The regulatory requirements for the Travel Rule in Estonia
From: "Vsevolod Gvardin" <[email-masked]>
To: "RAM Info"
Date: Tue, 19 Nov 2024 16:59:10 +0200

Dear Sirs,

I represent Sum and Substance Ltd., a UK-based company that provides a 
remote identity verification solution for AML-regulated companies.

We are currently conducting research on the implementation status of the 
Travel Rule in various jurisdictions to assist our clients in complying with 
their AML obligations. Unfortunately, there remains uncertainty regarding 
the regulatory requirements for the Travel Rule in Estonia.

The rules requiring the transmission of information about the originator and 
beneficiary accompanying the transfer of crypto-assets came into effect in 
Estonia on 15 March 2022. As of 30 December 2024, the rules set out in 
Regulation (EU) 2023/1113 will apply across the European Union. However, 
despite amendments made in 2024 to the Money Laundering and Terrorist 
Financing Prevention Act, which will come into force on 30 December 2024, 
these amendments will not affect the provisions concerning the Travel Rule, 
which will remain in the act until they are removed in 2026. We would be 
grateful if you could clarify why the provisions concerning the Travel Rule 
will remain in the text of the Money Laundering and Terrorist Financing 
Prevention Act until 2026, despite the entry into force of Regulation (EU) 
2023/1113.

We would appreciate your prompt reply.

Yours sincerely,

Vsevolod Gvardin