Crypto Banking

Estonia · CASP

Crypto banking for crypto-asset service providers authorised by Finantsinspektsioon

Estonia's FIU licences for virtual currency services lost their effect on 1 July 2026, and only Finantsinspektsioon or another EEA supervisor can now authorise crypto services there. The new regime is full financial supervision, not an AML registration. Start on a platform that is ready for it.

  • Crypto and euro positions per client on one ledger
  • Liquidity via Kraken
  • ICT and DORA documentation for Finantsinspektsioon
  • Client position exports for your wind-down plan
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Back-office dashboard with accounts and balances
Mobile banking app in your brand

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What a Finantsinspektsioon CASP authorisation lets you offer

Crypto custody

Each client holds crypto accounts with a deposit address and QR code. Keys run on custody infrastructure you contract, and you remain the custodian.

Exchange with euro on both sides

Buy and sell against euro, or swap one coin for another, with liquidity from a connected provider and the price and fee shown before confirmation.

Euro accounts

IBAN accounts from your banking partner with SEPA, SEPA Instant and SWIFT, kept on the same ledger as the client's crypto.

Mobile banking app with a branded Visa card added to Apple Wallet
Mobile banking app home screen with balance, Add money and Send buttons

Transfers out and between clients

On-chain withdrawals and internal transfers, with Travel Rule data exchanged through a connected provider.

Crypto-linked cards

Visa and Mastercard cards that spend crypto-linked balances and settle in euro. The card issuer contract is yours.

EEA clients from Tallinn

Once authorised, you notify the passport and serve other member states on the same platform.

What this licence does not cover

  • Running on an FIU licence for virtual currency services. The FIU cancelled those licences' register data on 1 July 2026.
  • Taking new clients while an application is still pending after 1 July 2026. Unauthorised providers may not open accounts or market their services.
  • Issuing e-money tokens, which need a credit institution or e-money institution.

What the regulator asks about your IT

Each requirement, what the platform gives you for it and who owns it after launch.

Exports of every client's crypto and euro positions, and a description of how wallets and accounts can be closed or moved to another provider.

You, with our input

Architecture, hosting, access roles, 2FA, audit trail, backups and incident handling documented for the file.

Crassula drafts, you adopt

Crypto per client on ledger accounts separate from your own, with exports to reconcile against the custody wallets.

Your operations team, on platform data

Withdrawal approvals and access roles in the back office, described as they work.

You, with input from us and the custody provider

The euro owed to each client on the ledger, ready to reconcile against your client money account.

Your finance team, on platform data

Onboarding questionnaires per client type, identity checks and screening through connected providers, client limits.

Your compliance officer

Originator and beneficiary data captured at onboarding and on each transfer, exchanged through a connected Travel Rule provider.

Your compliance officer

Service description, contract terms, audit and access rights, exit support.

You, with our input
Compliance documents card with created, sent, verification and accepted steps

Payment rails and providers

Rails your customers can use

SEPASEPA InstantSWIFTOn-chain transfersInternal transfers
Kraken

Kraken

MiCA-authorised by the Central Bank of Ireland and able to serve the EEA. Liquidity for your exchange service. Confirm with Kraken whether Kraken Embed is available for Estonian clients.

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Dates to plan around

Rules that change what you have to build, in the order they apply.

1 Jul 2024

Estonia's Market in Crypto-Assets Act enters into force, naming Finantsinspektsioon as the authority for CASPs.

30 Dec 2024

MiCA applies to CASPs, together with the crypto Travel Rule under Regulation (EU) 2023/1113.

17 Jan 2025

DORA applies to crypto-asset service providers.

23 Mar 2026

Finantsinspektsioon warns that firms applying late are unlikely to get a decision before the deadline and must submit wind-down plans.

1 Jul 2026

The transition ends. The FIU cancels the register data of virtual currency service licences, and only MiCA-authorised firms may serve Estonian clients.

Applying to Finantsinspektsioon as a CASP? Name us in your application.

Finantsinspektsioon looks at governance, capital, client assets, ICT and conduct, which is far more than the FIU ever checked. We give you a working platform and the technical part of the file, while your legal advisers handle the rest.

01

A platform you can demonstrate

A configured environment to show the regulator, not slides.

02

The technical part of your application, prepared

ICT systems, security and DORA, outsourcing and business continuity sections, plus data for your wind-down plan.

03

Providers lined up

Liquidity through Kraken, plus banking, custody and KYC providers from our network, matched to your licence.

Talk to us about your application

Crassula provides technology and documentation support. We do not provide legal or regulatory advice and cannot guarantee the outcome of an application.

Policy document prepared for a licence application
Create new wallet list with Bitcoin, Ethereum and Tether

How a launch usually runs

Picture a Tallinn team that held one of the last FIU licences and filed with Finantsinspektsioon in spring 2026. Its decision did not arrive before 1 July, so it stopped onboarding, kept existing clients informed and handed over the wind-down plan the supervisor had asked for. Its first product, built in-house, could not produce a clean per-client register of positions.

We set up the environment in its brand with Kraken liquidity and the custody infrastructure it contracts, and migrate its client balances onto the ledger. The ICT and DORA sections are rewritten around the new set-up, and the operations team shows Finantsinspektsioon a working reconciliation. Once authorised, it reopens sign-ups in Estonia and notifies its passport for Finland and Latvia.

For the regulatory background, read our guide to the Estonian VASP to CASP move and the MiCA CASP licence guide.

Read the licence guides

FAQ

No. Each firm had to file a full new application with Finantsinspektsioon. The FIU cancelled the register data of the old licences on 1 July 2026. Of the 641 licences valid in mid-2021, only 36 were still valid at the start of 2026.

A processing fee of EUR 3,000 applies to an authorisation application, and ongoing supervision fees follow once you are authorised.

Applicants still under review on 1 July 2026 could not keep serving clients, so the supervisor wanted proof that client assets could be returned or moved without harm. MiCA also requires an orderly wind-down plan from CASPs that hold client assets.

MiCA allows 25 working days to check completeness and 40 working days to decide, plus up to 20 working days of suspension when Finantsinspektsioon asks for more. Questions and gaps usually make it longer.

MiCA sets EUR 50,000 for class 1 services, EUR 125,000 for custody or exchange (class 2) and EUR 150,000 for a trading platform (class 3), or a quarter of last year's fixed overheads if that is higher.

No. Crassula is the software layer for accounts, exchange, apps and back office. Keys sit in the custody infrastructure you contract, and you answer for custody to clients and Finantsinspektsioon.

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