In Estonia Travel Rule requirements are set forth in the Money Laundering and Terrorist Financing Prevention Act ("Regulations").
Threshold
There is no reference to a de minimis threshold in Estonia.
Amount | Currency | Source |
N/A | N/A | N/A |
Required Originator and Beneficiary information vs Notabene system
Party to the TX | Required information (*) | IVMS field | Required? |
Originator | Name |
| Yes |
Originator | Identifier of the payment account or virtual currency wallet |
(transaction hash is also a parameter that VASPs can add) | Yes |
Originator | Residential address |
| OR |
Originator | Number of the identity document |
| OR |
Originator | Personal identification code |
| OR |
Originator | Date and place of birth |
| OR |
Beneficiary | Name |
| OR |
Beneficiary | Identifier of the payment account or virtual currency wallet |
| Yes |
⚠️ There are divergent interpretations of what originator information is required by § 25 (2/4), transcribed below. Hence, today, the Notabene system allows for a flexible implementation of the rules. The system currently only validates the fields marked as Yes in the table above and leaves it to the VASPs' discretion to decide what additional originator information should be included.
(2/4) When performing a transaction of exchange or transfer of virtual currency, the transaction initiator’s provider of virtual currency service ascertains the identity of each customer according to the provisions of §§ 21 and 22 of this Act, and, with respect to the initiator, collects at least the following particulars:
1) for a natural person – the person’s name, unique identifier of the transaction, identifier of the payment account or virtual currency wallet, the title and number of the identity document and personal identification code or date and place of birth and residential address;
⚠️ The IVMS standard does not include a specific field for personal identification code. Originator VASPs can add the PIC to the <customerIdentification> field. To help the Beneficiary VASP understand that the number in the <customerIdentification> is the PIC, the Originator VASP should add PIC before the number (e.g., customerIdentification = PIC 14548252976).
⚠️ Unlike most Travel Rule regulations and contrary to FATF Guidance, Estonia does not require VASPs to collect and transmit any personal information about the Beneficiary customer (see transcribed section below). Most jurisdictions require VASPs to send (and receive) the name of the Beneficiary. Without Beneficiary name, it is not possible to carry out sanction screening on the counterparty customer. Additionally, Beneficiary VASPs from other jurisdictions may deem the Travel Rule transfer to be incomplete if Beneficiary name is not included. Hence, this field is not being validated as mandatory, but can optionally be included in Travel Rule transfers
(2/5) When effecting a transaction of virtual currency exchange or transfer, a provider of virtual currency service collects, with respect to the virtual currency or to the recipient of the transfer, the particulars of the transaction’s unique identifier and, where the particulars of the identifier of a payment account or virtual currency wallet are used to perform the transaction, also those particulars.
(*) According to Article 25 (2/7), (2/4) and (2/5) of the Regulations
(**) YES = Required ; OR = Alternative fields