According to the assessments made by the Financial Intelligence Unit, the company lacked, amongst other things, systems, risk management and procedural rules – appropriate to the nature, scope, and complexity of its economic activity – to prevent money laundering and terrorism financing. Also, the company did not have enough human resources to fulfil the tasks in compliance with the law, including the know-your-customer principle and the implementation of mandatory due diligence measures.
Mobilum OÜ was a virtual asset service provider with one of the largest turnovers until the revoking of the license. The individuals associated with the enterprise had no connections with Estonia, and most of the active customer base of the company was located outside the European economic area.
The Financial Intelligence Unit concluded that due to the circumstances identified in the supervision proceedings, the risk of money laundering and terrorism financing and financial sanctions remains unmitigated in the company.
Mobilum’s authorisation for offering virtual asset services was valid during 31 October 2019 until 4 March 2023.
118 activity licenses in Estonia were valid for the providing virtual asset services in the beginning of March 2023. The amendments of the Money Laundering and Terrorist Financing Prevention Act took effect on 15 March 2022, which obligated the virtual asset service providers to adjust to the amendments by 15 June 2022.