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Lithuanian Firms Must Comply with AML Regulations: Compliance Officer Key to Success

In an effort to combat money laundering and terrorist financing, the Lithuanian government has implemented strict regulations for financial institutions and obliged entities. The role of a compliance officer is crucial in ensuring that these institutions adhere to the Prevention of Money Laundering and Terrorist Financing Law.

Designation of Compliance Officer

According to Article 22 Part 1 of the law, financial institutions and other obliged entities must designate senior employees or board members to implement anti-money laundering (AML) measures and liaise with the Financial Crime Investigation Service. The designated officer must be notified in writing within seven working days of designation or replacement.

Requirements for AML Compliance Officer

Only a person with:

  • Education
  • Professional aptitude
  • Abilities
  • Personal qualities
  • Experience
  • Impeccable reputation

can be appointed as an AML compliance officer. The company must also provide specialized training on measures to prevent money laundering and the financing of terrorism to its employees.

Responsibilities of the Compliance Officer

The compliance officer is responsible for:

  • Developing, implementing, and maintaining an anti-money laundering program
  • Collecting and analyzing information on suspicious transactions and reporting to FCIS
  • Preparing and submitting written statements on compliance with the law
  • Maintaining high-risk customer records
  • Reporting to authorities

Due Diligence Measures

Due diligence measures must be taken when:

  • Establishing business relations with new clients
  • Making payments over 15,000 EUR
  • Verifying data in case of doubts about reliability
  • Suspected money laundering or terrorist financing

Frequently Asked Questions

Q: To which position should the compliance officer be assigned?

A: The compliance officer is an employee of the company or a part of the governing body, performing duties based on an employment agreement.

Q: Which unit is responsible for reviewing the work of Compliance Officer?

A: The contact person is directly subordinate to the Directors of the credit or financial institution and has access to relevant information in all structural divisions of the financial institution.

Q: Should the compliance officer be experienced?

A: Yes, it is required to have experience in this area. Only a person with education, professional aptitude, abilities, personal qualities, experience, and impeccable reputation can be appointed as the KYC/AML Officer.

Q: Is the compliance officer mandatory from the beginning of crypto company’s operations?

A: Compliance Officer must be assigned to duty not later than seven days after informing Registru Centras that the company will perform virtual currency exchange and/or depository virtual currency wallet services.

Q: Is it allowed to hire the Compliance Officer outside of Lithuania?

A: Yes, there are no specific laws determining nationality or living address of the specialist.

KYC/AML Officer Service Fee

  • 750 EUR/month (minimum period of service order - 6 months)