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According to the agreement, CASPs will need to apply customer due diligence measures when carrying out transactions amounting to €1000 or more. It adds measures to mitigate risks in relation to transactions with self-hosted wallets.
Source...
The information is outdated. Estonia has now tightened its crypto regulation. Many companies have lost their licenses. The minimum authorized capital is 250k, if I remember correctly. Plus strict requirements for company directors. So if you don't have a big budget, it's better to look towards...
AFAIK you have no chance getting EMI/Bank account opened for Ru citizen nowadays, unless he has EU residence permit.
You may try to look in to UAE or something similar, that doesn't give such pressure on Russia.
Good luck and please keep us up to date on your issue.