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The standards we advise on, applied to ourselves

As a provider of legal and accounting services, Averium is an obliged entity under the Estonian Money Laundering and Terrorist Financing Prevention Act. This page sets out our AML and KYC procedures, the work we refuse, and the terms of every engagement.

A steel ruler beside a small glass balance scale on white paper

What we are and what we are not

What Averium is

  • A professional services firm registered in Estonia, registry code 17232358.
  • An agent acting in your name and on your behalf under a written mandate (power of attorney).
  • A provider of consulting and legal services in Estonia, and in other EU member states through partner law firms.
  • An obliged entity under the Estonian Money Laundering and Terrorist Financing Prevention Act.
  • On your side only, in every dealing with banks and EMIs.

What Averium is not

  • A financial institution.
  • A holder of client money: we do not hold, custody or transfer client funds.
  • A provider of payment, e-money or crypto-asset services.
  • A nominee director or nominee shareholder.
  • An adviser on transactions designed to circumvent sanctions.

Six controls behind our AML and KYC procedures

Every client file passes the same six controls, from the first identity check to the end of the five-year retention period.

Client due diligence

Corporate documents, beneficial owners to the natural person, signatory ID, business and source of funds. Enhanced checks for PEPs, complex structures and high-risk third countries.

Sanctions screening

Clients, beneficial owners and counterparties are screened against EU, UN, UK (OFSI) and US (OFAC) lists at onboarding and on every new matter.

Risk appetite

No advice on transactions designed to circumvent sanctions. No nominee director or shareholder services. No crypto custody, exchange or payment services. No client funds.

Internal roles

The Head of Operations is the compliance contact; the Head of Legal Practice approves each new client file. Suspicious activity goes to the Financial Intelligence Unit (RAB).

Record-keeping

Engagement files, KYC records and invoices are kept for five years after the relationship ends, as Estonian law requires.

Data protection

Client data is processed under the GDPR. Documents are stored in EU-hosted systems with two-factor access. Messages sent through the form on this site reach info@averium.ee through our email delivery provider and are used only to answer you. To see, correct or delete your data, write to info@averium.ee; you may also complain to the Estonian Data Protection Inspectorate. Our privacy policy, linked at the foot of every page, sets out the details.

Clients we do not serve

We do not onboard sanctioned persons, or clients who are residents of, or beneficially owned from, the prohibited jurisdictions listed in our Prohibited and Restricted Jurisdictions Policy. Clients connected with high-risk jurisdictions are accepted only after enhanced due diligence. The check runs before engagement and again on every new matter.

Engagement terms

Fees are quoted per matter after the scoping call. How we engage does not change from one matter to the next.

  1. Written scope

    Every matter starts with a written scope, agreed before work begins.

  2. Fixed fee

    Each matter has a fixed fee, stated in the proposal. Fixed-fee matters start on a 50% prepayment (certain engagements may require 100% prepayment, as stated in the proposal).

  3. Monthly retainers

    Ongoing compliance and accounting run on monthly retainers, invoiced monthly with a 14-day payment term.

  4. Official fees at cost

    State, notary, EUIPO and translation fees are re-invoiced at cost.

  5. One engagement, invoiced in EUR

    Cross-border matters run with partner law firms under one engagement with us. All invoices are issued in EUR.

Start with a scoping call

Describe the task and the deadline. We reply within one business day, then send a written scope and a fixed fee.

Write to us

Eight steps, every matter

KYC comes before the proposal. Delivery starts once the engagement letter is signed and the prepayment is received.

  1. 01

    Enquiry

    Send the task through the form or to info@averium.ee. A short description of the company and the deadline is enough to start.

  2. 02

    Scoping call

    Within one business day we arrange a call to confirm the task, the documents involved and the timeline.

  3. 03

    KYC and sanctions screening

    We identify the client and its beneficial owners and screen them against EU, UN, UK and US sanctions lists, as the law requires.

  4. 04

    Proposal with a fixed fee

    You receive a written scope and a fixed fee, with official fees listed separately and re-invoiced at cost.

  5. 05

    Engagement letter and power of attorney

    The engagement letter sets the terms. The power of attorney lets us act in your name before registries, authorities and counterparties.

  6. 06

    50% prepayment

    Fixed-fee matters start once the 50% prepayment is received (certain engagements may require 100% prepayment, as stated in the proposal). All invoices are issued in EUR.

  7. 07

    Delivery with milestone updates

    We draft, file and negotiate, and report at each milestone, so you always know where the matter stands.

  8. 08

    Final invoice or retainer

    The balance is invoiced on completion. Ongoing compliance and accounting continue on a monthly retainer with a 14-day payment term.

Questions about how we work

No, and nobody honest can: the bank always makes the decision. We do what actually improves the odds: we choose a bank or EMI whose risk appetite matches your model, prepare a complete file the first time and answer the bank's questions on time. If the scoping call shows there is no realistic chance, we tell you before you pay.

Online, when every founder and board member has an Estonian digital ID (e-Residency card, ID card, Mobile-ID or Smart-ID), the Business Register reviews a qualifying application by the next working day in the expedited procedure; without an e-Residency card yet, allow several weeks to get one. Through a notary, the register reviews the application within five working days. In our experience an EMI account opens in a few days to three weeks, and an Estonian bank account in 3-8 weeks, depending on the business's connection to Estonia. We fix the exact timeline in the proposal.

It means launching your crypto product in the EU with an authorised CASP as the regulated provider: the partner provides the crypto-asset services under its own authorisation, your users become its clients, and your company keeps the brand and the product. Your company needs no MiCA authorisation of its own, so MiCA's capital requirement does not apply to it; it follows the partner's compliance rules instead. It suits exchanges, wallets and brokerage services that need to launch now and obtain their own licence later; payment features with e-money tokens also need a partner with a payment licence. We choose the partner, check its licence and negotiate the agreement on your side.

Yes. Most of our clients are Estonian companies with foreign owners from the EU, the UK, Canada and other countries. There is one condition: the client and its beneficial owners pass our due diligence and fall outside the restrictions of our client acceptance policy.

Usually not. Under a power of attorney we act for you before the Business Register, banks and the Tax and Customs Board. Documents are signed digitally (e-Residency card, Smart-ID or Mobile-ID), remotely with an Estonian notary, or before a notary in your country with an apostille where Estonian law accepts that. You appear in person to collect an e-Residency card (at an Estonian embassy or another official pickup point), to apply for a residence permit (fingerprints are taken), and at banks that identify non-residents only face to face.

Write to us the same day: bank requests come with hard deadlines, and the strategy of the reply matters more than the request itself. We find out the real reason, prepare an answer to every point, open a back-up account in parallel and challenge the refusal where it is unfounded.

Corporate documents, the beneficial owners down to the natural person, ID verification of the people who sign, and a written description of the business and its source of funds. For politically exposed persons, complex structures and high-risk third countries we apply enhanced due diligence.

No. Averium does not hold, custody or transfer client funds, and does not act as nominee director or shareholder. Clients pay their own capital contributions and third-party fees directly.

We keep what you tell us confidential, under our engagement agreement and under the Law of Obligations Act, which binds every provider of services under a mandate. We share your information only to carry out your instructions or where the law requires it, for example under the anti-money-laundering act. Documents are stored in the EU, and partner firms receive only what their part of the work needs, under an NDA. Our privacy policy, linked at the foot of every page, sets out how we process your data; questions about your data go to info@averium.ee.

Yes: through partner law firms in 36 jurisdictions, under one engagement with us. We represent clients in disputes only in Estonia; a dispute in another country runs with a partner law firm.

Describe
your task

Tell us what needs to be done and by when. We reply within one business day to arrange a scoping call.