Self-custodial wallet / non-custodial software in Finland

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.

Custody Providers: Entities providing "custodial wallet services" are also explicitly defined as "virtual currency providers" and require registration with the FIN-FSA. This includes services where the private keys are held by the provider on behalf of the client.

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).

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.

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

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

Assessment Phase: Conduct a thorough audit of existing operations to identify gaps relative to MiCA’s requirements.

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

2026: Full enforcement across all covered activities.

Evidence fact fi.enforcement.the-primary-legal not found (may have been renamed).

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.

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.