Subject: RE: AML officer
From: rahapesu - RAB <[email-masked]>
To: 'Lilita Knapsa' <[email-masked]>
Date: Fri, 7 Nov 2025 11:49:18 +0000

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 | www.fiu.ee<https://www.fiu.ee/>

From: Lilita Knapsa <[email-masked]>
Sent: Friday, October 24, 2025 8:12 AM
To: rahapesu - RAB <[email-masked]>
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