Your Estonian gambling licence requires a contact person appointed by your management board and coordinated with the Financial Intelligence Unit (FIU). We provide a qualified AML professional based in Estonia, and a clear framework to onboard them into your business.
Request a proposalBook a free 30-minute consultation
Free consultations are available until 20 December 2026.
AML/CFT specialists since 2008, with our own team in Estonia
Your deadline
Gambling Act section 18(3¹) and (3²), and section 102(5) and (8).
The contact person must work permanently in Estonia and meet the requirements of the Money Laundering and Terrorist Financing Prevention Act (section 17). Three points decide how much time you need.
Many operators already have a contact person who is based abroad or not employed in Estonia. Under the new rules, the contact person must work permanently in Estonia, be registered in TÖR and be coordinated with the FIU.
The FIU will assess the candidate’s suitability, and expects the contact person to know your business, risks and systems, not only the law.
14%
In its feedback for 2025, the FIU found that only about 14% of reports from gambling operators were based on suspicion, and only 17 of 45 licensed operators filed any report.
Source: FIU feedback to gambling operators, 2025
An experienced AML professional with at least 3 years of experience in FIU reporting, or prior experience as an FIU contact person.
A checklist of the documents, data and system access your contact person needs, and support for the contact person in learning your business and the new role.
FIU correspondence handled in Estonian and forwarded to you in English, report coordination, regulatory updates and quarterly reports to your management board.
A professional who performs the role, with a team behind them. Your contact person is an AML professional you can rely on, who learns your business, takes part in your compliance work and reports to your management board. Complium stays alongside the contact person and your company for the whole engagement.
Every step shows who is responsible and what is needed, so nothing comes as a surprise.
We discuss your licence type, your deadline and your current AML set‑up.
You complete a short questionnaire on your operations and AML framework, so we can assess the engagement.
We propose a candidate who meets the statutory requirements, and your company employs them under an employment contract. We share guidance on how to register the employment with EMTA.
We share our onboarding checklist. You onboard your new employee properly into your company, with the documents, data and system access the role needs.
Your management board appoints the contact person and submits the appointment for coordination with the FIU.
The FIU’s assessment can take up to one month and may include an interview, so the contact person must know the basics of your internal compliance rules by then. Once the FIU accepts the appointment, the work begins.
Allow up to six weeks: about two weeks of onboarding after signing, plus up to one month for the FIU’s assessment.
To perform the duties set by law, the contact person needs to know both the legal requirements and your business. Our onboarding checklist, built on FIU guidance, sets out what your company provides and which topics the contact person must master.
The contact person is employed by your company and registered in the Estonian employment register (TÖR), as the law expects. The FIU does not require the position to be full‑time: we help you estimate the minimum hours the role needs.
An existing group MLRO can continue to run the AML programme. The contact person is your point of contact with the FIU and your reporting function in Estonia.
The fee is based on the hours the role needs, as estimated from the onboarding questionnaire.
Employing a contact person in Estonia brings local payroll and registration duties. On request, Complium supports your company with both, so the employment runs correctly from the first month.
Monthly salary calculation, employment tax returns (TSD) and payment instructions, arranged by Complium through our partner accountant in Estonia.
Support with access to the Tax and Customs Board portal (e‑MTA), registration in the employment register (TÖR), and sick leave certificate data for the Health Insurance Fund, submitted through the state portal eesti.ee.
Approval, timing, employment and how the role fits your current AML set‑up.
The decision is the FIU’s. Every candidate we propose meets the statutory requirements. If the FIU does not approve the appointment, we discuss a replacement candidate with you.
Yes. The group MLRO can continue to run your AML programme. The Estonian contact person acts as your point of contact with the FIU and your reporting function in Estonia.
The onboarding period is about two weeks after signing. The time the FIU needs for coordination comes on top of that, so we recommend starting well before your deadline.
Yes. The contact person receives FIU correspondence in Estonian, forwards it to your team in English and handles the response within the deadline.
Your company does. The contact person is registered with EMTA in the employment register (TÖR) as your employee and works for your foreign entity under an employment contract governed by Estonian law.
A foreign company without an Estonian branch registers with EMTA as a non‑resident employer before the employment starts. It then registers the employee in TÖR, withholds and pays the Estonian employment taxes and files the monthly TSD return by the 10th day of the following month. Complium can arrange this through its payroll service.
Because the contact person lives and works in Estonia, the salary is taxed in Estonia. Your company must also reflect this employment in its own accounting in your home country. Please confirm with your local financial or tax adviser how to record it before the employment starts, so that no double taxation arises.
Tell us about your licence, your deadline and your current AML set‑up. We’ll come back with a candidate plan, the hours the role needs and a monthly fee.
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