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Financial Institutions Established in Lithuania Subject to AML Scope

Lithuanian financial institutions, including e-money and payment institutions, whose head office is located in another EU Member State but provides services in Lithuania through branches or agents, are also subject to the Lithuanian Anti-Money Laundering (AML) scope.

Regulatory Framework

The Bank of Lithuania issues instructions for businesses and supervises their AML measures, while the Financial Crime Investigation Service (FCIS) is responsible for receiving suspicious transaction reports and notifications about compliance officer appointments. Businesses must implement AML policies and procedures, conduct customer due diligence, and comply with requirements for face-to-face and remote identification.

Implementation of AML Measures

  • Implement AML policies and procedures
  • Conduct customer due diligence
  • Comply with requirements for face-to-face and remote identification

Customer Due Diligence

Before establishing a business relationship or carrying out transactions exceeding certain thresholds, businesses in Lithuania must undertake Customer Due Diligence (CDD) to identify and verify customers’ identity. CDD includes obtaining information on the purpose and intended nature of the business relationship or transaction.

KYC Requirements

Identification and Verification

  • Know Your Customer (KYC) is an essential part of CDD
  • Businesses must obtain specific information from natural and legal persons for their identification and verification

Remote KYC Requirements

In certain cases, businesses are allowed to identify and verify customers remotely using electronic identification schemes or other remote verification solutions.

Reporting Suspicious Transactions

Timely Reporting Required

  • During CDD and ongoing monitoring, businesses must pay attention to suspicious transactions and report them to the FCIS within three working hours from detection

Key Takeaways

Lithuania is an attractive jurisdiction for payment and e-money institution licensing due to its fast licensing process, newcomer program, and friendly investment environment. To benefit from this promising fintech hub, businesses must ensure compliance with current and future regulations.

Where to Find Out More

Useful Resources

  • Bank of Lithuania - EMI licensing requirements
  • Bank of Lithuania - PI licensing requirements
  • Bank of Lithuania - Recommendations for license applicants
  • Lithuania’s Centre of Excellence in Anti-Money Laundering

Stay Compliant with AML/KYC Regulations

Let us help your company stay compliant with AML/KYC regulations in Lithuania. Contact us today to learn more about our services and how we can support you in navigating the regulatory landscape.