← Regulations / Finland / Operating Models / CEX

Centralized exchange in Finland

Order-book exchange that takes custody of user assets and matches trades between users.

Conditional AI-Generated · Unreviewed

CEX is conditionally permitted in Finland with a local entity, subject to AML obligations and high licensing burden.

Verdict Details

Permitted
conditional
Local entity required
Yes
Licensing burden
High
Last updated
2026-07-13

AML Obligations

  • Registration as a virtual currency provider (VCP) with the FIN-FSA under the Act on Virtual Currency Providers (572/2019)
  • Full customer due diligence (CDD) under AML/CTF obligations — risk assessment, identity verification, beneficial ownership checks
  • Enhanced Due Diligence (EDD) for high-risk transactions
  • Real-time transaction monitoring systems for KYC/AML compliance and data reporting under MiCA
  • Travel Rule obligations: collect, verify, and transmit sender/recipient names and addresses, transaction description (amount and crypto type), and purpose of transfer (if known) on all crypto transfers
  • Suspicious transaction reporting (STR) to the Financial Intelligence Unit (FIU) at the National Bureau of Investigation
  • Mandatory transparency disclosures on the nature, risks, and costs of crypto assets
  • Professional indemnity insurance (no specific minimum share capital requirement under Finnish law for VCPs)
  • Market makers, custodial services, and exchanges must comply with stringent operational standards under MiCA

Key Restrictions

  • The applicant must be a Finnish limited liability company (osakeyhtiö) or a branch of an EEA-incorporated company
  • Management (CEO and at least one other board member) must be located in Finland
  • Custodial services require VASP registration — private keys held by the provider on behalf of clients triggers regulatory obligations
  • MiCA full enforcement applies from 2026, with gradual rollout phases in 2024–2025 affecting broader categories of crypto service providers
  • Mandatory transparency disclosures and clear terms of use with accessible customer support must be provided

Key Risks

  • Enforcement precedent: FIN-FSA has issued public reprimands (Coinmotion Oy, 2022) and public warnings (Tesseract Finance Oy, 2023) for CDD and registration deficiencies — demonstrates active supervision
  • Operating without proper registration or with AML deficiencies can result in formal disciplinary marks on the regulatory record (public warning / public reprimand)
  • Travel Rule compliance requires robust cross-border coordination infrastructure — gaps in data transmission with counterparties are a common compliance gap
  • Regulatory burden will increase under MiCA as full enforcement approaches in 2026 — early engagement with FIN-FSA is recommended

Evidence

This verdict synthesizes the following facts. Each fact links to its primary source(s).

licensing 20% confidence

Financial Supervisory Authority (FIN-FSA): The primary regulator responsible for authorizing and supervising all crypto-asset service providers, ensuring compliance with anti-money laundering (AML), consumer protection standards, and operational requirements.

licensing 20% confidence

Financial Intelligence Unit (FIU): Operates within the National Bureau of Investigation to receive and investigate suspicious transaction reports from crypto service providers, focusing on preventing money laundering and terrorist financing.

licensing 20% confidence

Issuance of licenses for providers offering stablecoins and other crypto assets.

licensing 20% confidence

Obligations for market makers, custodial services, and exchanges to comply with stringent operational standards.

licensing 20% confidence

2024-2025: Gradual rollout affecting broader categories of crypto service providers.

licensing 20% confidence

2026: Full enforcement across all covered activities.

licensing 20% confidence

Mandatory transparency disclosures regarding the nature, risks, and costs associated with crypto assets.

licensing 20% confidence

Requirements for clear terms of use and accessible customer support mechanisms.

aml 60% confidence

Providing services for exchanging virtual currency and fiat currency: This covers entities facilitating the purchase or sale of virtual currencies using traditional currencies (e.g., EUR, USD).

aml 60% confidence

Providing custodial wallet services: This refers to services where an entity holds, stores, or transfers virtual currencies or private cryptographic keys on behalf of customers.

aml 60% confidence

Exchanges: Both exchanges offering fiat-to-crypto and crypto-to-crypto trading services are clearly defined as "virtual currency providers" and require registration with the FIN-FSA.

aml 60% confidence

The applicant must be a Finnish limited liability company (osakeyhtiö) or a branch of a limited liability company incorporated in an EEA country.

aml 60% confidence

The management of the applicant must be located in Finland. This includes the CEO and at least one other member of the board of directors.

aml 60% confidence

Capital Requirements (Professional Indemnity Insurance):

travel-rule 20% confidence

Objective: Prevent illicit activities by making it difficult for criminals to use money laundering techniques across borders.

travel-rule 20% confidence

Names and addresses of the sender and recipient

travel-rule 20% confidence

Description of the transaction (including amount and cryptocurrency type)

travel-rule 20% confidence

Purpose of the transfer (if known)

travel-rule 20% confidence

Compliance Infrastructure: Integrate robust systems for real-time collection, verification, and transmission of required data points.

travel-rule 20% confidence

Enhanced Due Diligence (EDD): Additional layers of verification for high-risk transactions may be necessary.

enforcement 50% confidence

Entity Targeted: Tesseract Finance Oy (now operating as Stableton). Violation Type: Providing virtual currency services without proper registration for a period, and deficiencies in internal control mechanisms, risk assessment, and customer due diligence processes for Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF). Penalty Amount: Public warning (julkinen varoitus). While not a monetary fine, it's a formal and significant disciplinary measure by the FIN-FSA, obliging the company to rectify its shortcomings. Outcome: The company was required to implement corrective measures to comply with the Virtual Currency Providers Act and AML/CTF obligations. The public warning serves as a significant mark on the company's regulatory record.

enforcement 50% confidence

Entity Targeted: Coinmotion Oy (a registered virtual currency provider in Finland). Violation Type: Deficiencies in compliance with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) obligations, specifically regarding customer due diligence, risk assessment, and internal control. The FIN-FSA found that Coinmotion's practices did not fully meet the requirements of the Act on Virtual Currency Providers and the Anti-Money Laundering Act. Penalty Amount: Public reprimand (julkinen huomautus). Similar to the public warning, this is a formal, non-monetary disciplinary action, indicating serious shortcomings that required immediate correction. Outcome: Coinmotion Oy was instructed to rectify the identified deficiencies in its AML/CTF processes to ensure full compliance with regulatory requirements.

enforcement 50% confidence

Outcome: The company was required to implement corrective measures to comply with the Virtual Currency Providers Act and AML/CTF obligations. The public warning serves as a significant mark on the company's regulatory record.

enforcement 50% confidence

Outcome: Coinmotion Oy was instructed to rectify the identified deficiencies in its AML/CTF processes to ensure full compliance with regulatory requirements.

enforcement 50% confidence

Legal Basis: The primary legal framework is the Act on Virtual Currency Providers (572/2019), which came into force in Finland on May 1, 2019. This Act places virtual asset service providers (VASPs) under the supervision of the Finnish Financial Supervisory Authority (FIN-FSA) and subjects them to AML/CFT obligations akin to traditional financial institutions.

Verdict Attribution

Source:
AI-Generated · Unreviewed
AI synthesized:
2026-07-13 (deepseek-chat)
Last updated:
2026-07-13
Confidence:
medium

This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.

Conditional — a centralized exchange operating in Finland must register as a virtual currency provider with the FIN-FSA, be a Finnish (or EEA-branch) limited liability company with management located in Finland, comply with full AML/CTF and Travel Rule obligations, and prepare for MiCA's full enforcement by 2026.

Questions this verdict aims to answer

  • What exchange / VASP license applies?
  • What custody segregation rules apply to user assets?
  • What market-conduct and listing rules apply?
  • What travel-rule obligations apply on withdrawals?