Ancient source of Bitcoins in Tallinn, Estonia.
Threat E-mail from Estonian Police

The e-mail below, from Estonian policeman Urmas Pai, made me decide to stop any Bitcoin related activity in Estonia. In it Urmas Pai is threatening me with 3 years in prison and a 32,000 Euro fine. From this point on it is more than clear that the police seek information from me with the purpose of using it against me in order to either fine me or give me a prison sentence.

From this point on I believe that I do not have any obligation to cooperate with an investigation against myself. At least I would not if the East European country lived up to the Western-style democratic principles it claims to want to espouse, but unfortunately old Soviet habits appear to die hard. The courts later ruled that I must cooperate with this investigation against myself.

They also want "Copies of ID-s of clients", without any restrictions.

The crucial part in this e-mail is the threat of starting a criminal investigation for "doing business without being previously registrated [sic]", and that this is "punishable by a pecuniary punishment or up to 3 years imprisonment".

The highlights in red are by Urmas Pai himself.

From: Urmas Pai
To: Otto de Voogd 
Subject: RE:
Date: Thu, 13 Feb 2014 12:46:50 +0000

Bitcoin suits under criteria of alternative means of payment according to Money Laundering and Terrorist Financing Prevention Act (RahaPTS) § 6 lg 1 p 4 (, therefore the demands of the law should be followed while providing the mentioned service.


As far as we see, the service is provided for everybody on website (registered in Estonia) and you have registered that webpage. We are intrested in information who is providing the service (is it some legal person or private person) and if AML law is followed. As we see, the transactions of selling and buying of bitcoins can be made on webpage and everybody can to that. That is the difference between offering the service and just doing transactions with friends (occasional transactions is not offered for everybody, therefore in most of times it can not be handled as offering the service).


Documents we are asking to see are compulsorary by the law as shown:

1)      Copies of ID-s of clients - § 23 lg 1

2)      Internal measures or procedure of due diligence . § 29 lg 1

3)      Registration - § 52 lg 1 p 5


Also, doing business without being previously registrated (§ 52) may cause a criminal investigation according to Estonian Penal Code:

Division 1 Illegal Economic Activities

§ 372. Economic activities without activity licence and prohibited economic activities

(1) Economic activities in a field subject to a special prohibition, or activities without an activity licence, other licence, registration or through an unapproved enterprise in a field where such activity licence, other licence, registration or approval of enterprises is required,
is punishable by a fine of up to 300 fine units or by detention.

(2) The same act, if:
1) it is committed by a person who has previously been punished by such act;
2) danger to the life or health of numerous people is caused thereby, or
3) it is committed within a field of activity related to health services, handling of infectious materials, aviation, railway traffic or provision of credit, insurance or financial services,
is punishable by a pecuniary punishment or up to 3 years’ imprisonment.

(3) An act specified in subsection (1) of this section, if committed by a legal person,
is punishable by a fine of up to 32,000 euros.
[RT I 2010, 22, 108 - entry into force 01.01.2011]

(4) An act specified in subsection (2) of this section, if committed by a legal person,
is punishable by a pecuniary punishment.

(5) A court may, pursuant to the provisions of § 83 of this Code, apply confiscation of a substance or object which was the direct object of the commission of an offence provided for in this section.
[RT I 2007, 13, 69 - entry into force 15.03.2007]


Best regards




Urmas Pai


Estonian Financial Intelligence Unit

Tööstuse Street 52, 10416 Tallinn, Estonia
tel. secretary +372 6 123 840
tel. direct +372 6 123 859
fax +372 6 123 845



This e-mail and any attachments may contain confidential and privileged information. If you are not the intended recipient, please notify the sender immediately by return e-mail, delete this e-mail and destroy any copies. Any dissemination or use of this information by a person other than the intended recipient is unauthorized and may be illegal.

Yet both the appeals court and supreme court maintained that a criminal investigation was not foreseeable.

See the full e-mail conversation with Urmas Pai.

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