Overview of Crypto Regulation in Lithuania

Cost Of Cryptocurrency License In Lithuania valid until 30.12.2025

Choose the best package of services for obtaining a crypto license in Lithuania

Ready-made company with obtained VASP registration

Full set up of the VASP business with all the necessary infrastructure, connection to KYC providers, local substance and Accounting services

€25000

• Full Turnkey Company Transfer

• VASP registration

• Address of registration for 1 year

• Registered share capital ( EUR 125,000)

• Individual AML/KYC Policy

• Handling the communication with the Financial Crime Investigation Service (FCIS/FNTT)

• Search for premises for rent

• Apostilled and Translated set of corporate documents

• Assistance in opening segregated Bank accounts (C2B/B2B) under guarantee key result

• Company’s name change

Procedure for obtaining a Crypto License in Lithuania valid until 31.05.2025

After 6-8 weeks company will be fully registered as a Virtual Asset Service Provider and 2-3 weeks will be required extra to become fully operative and open a Bank account

PRELIMINARY PROJECT ASSESSMENT

1-2 days

Result: All the needed documents for the process initiation are collected.

Collecting preliminary set of the documents from the Client side:

• An up-to-date copy of the passport of the country of residence (scan)

• A business model of the company (brief description 1-2 A4 pages)

• Preferred company name is provided

• Filled customer profile(s) from all the participants of the project are collected

• Address of residence for each participant is provided

• Budgets and scope of the project are approved according to the initial workshop

• Gofaizen & Sherle operational department has drafted PoA and shared it with the Client along with further steps

COMPANY TRANSFER PROCESS

4-6 weeks

Result: VASP company with registered share capital (EUR 125,000) is transferred to a client’s favor and fully compliant with the law

• Preparation and submission of the public announcement and decision of the director of the name change to the commercial registry of Lithuania

• Preparation and submission of the decision of the director change to the commercial registry of Lithuania

• The Client will be presented with a list of 30-40 questions (to identify risk appetites, the geography of the customers, the nature of the business, etc.)

• Integration of the answers into the main set of documents (adaption of customer due diligence measures, implementations of sanctions, collecting and storing data, principles of verification, etc.)

• Preparation of the Power of Attorney, confirmation for the notary deal, JAR-PSA forms, and other related documentation

• Arrangement and conduction of a notary deal

• Documents translation

• Submission of information to the Registry of Shareholders (JADIS)

• Submission of information to the Registry of Beneficiaries (JANGIS)

• Changing of the company contact data in the commercial registry

• Corporate document collection, translation, and notarization

• Search for premises for rent based on the Client preferences (size, cost, location, infrastructure)

CORPORATE ACCOUNT OPENING AND ACCOUNTING

2-4 weeks

Result: The company has an operational corporate account under crypto with connected accounting service

• Analysis of the most suitable Banks/EMIs, comparison of the risk appetite of the Bank in relation to the risk appetite of the Client based on previously prepared AML policies (Done simultaneously with premise search)

• Collection of necessary documents from the Client side to initiate the process (flow of funds, source of wealth, description of the purpose of opening an account, key partners, company website, utility bill, etc.)

• Initiation of the onboarding procedure simultaneously in 2-3 crypto friendly EMI’s

• Guiding the Client’s company through the entire process of opening an account

• Acquiring connection (if necessary)

Standard Tax Rates in Lithuania

The cost of obtaining a crypto exchange license in Lithuania is notably competitive compared to other EU countries. This reasonable cost, coupled with a streamlined licensing process, makes Lithuania an economically one of the most attractive jurisdiction for crypto businesses in EU. The expenses involved in securing a license can vary based on the type of VASP license and the scope of operations.

Despite these costs, they remain lower than in many other European jurisdictions, positioning Lithuania as a financially viable option for crypto enterprises.

In addition to a favorable regulatory and economic environment, Lithuania offers potentially lower operational costs and fast process. This combination of affordability and efficiency makes Lithuania a prime destination for both startups and established firms aiming to optimize their investment.

FCIS (FNTT) as Lithuanian supervisory body for VASP’s

Register of licensed crypto companies is kept by Lithuania Centre of Register, however activities related to virtual assets are supervised by Financial Crime Investigation Service (FCIS, in Lithuanian: Finansinių nusikaltimų tyrimo tarnyba or FNTT) – law enforcement agency under the Ministry of the Interior, which is part of Financial Intelligence Units’ international network. FCIS activities are aimed to prevention of money laundering, terrorist financing and violation of sanctions. Lithuanian FIU is also responsible for investigations related to financial crime, including VAT-related and other tax machinations, money laundering, and illegal receipt or use of financial assistance from the EU. FCIS is actively participating in National Crime Prevention and Combating Corruption Program and constantly developing methods to engage society in the fight against financial crime. This authority regularly issues orders describing certain aspects of legislation in the AML/CTF field, which are directly applicable to the relevant obliged entities.

Supervision under crypto projects is primarily performed by FCIS through targeted inspections which are planned 1 year in advance. FCIS is publishing list of companies being supervised this way at the beginning of the year, however unplanned targeted supervision also possible in certain circumstances.

In 2023 FCIS also introduced regular reporting for VASPs, which shall be performed annually. Such approach certainly will affect market’s transparency and allows performance of more effective supervisory approach.

AML Officer

Lithuanian AML law requires from VASPs to appoint appoint AML Officer (leading employee) who would organize the implementation of money laundering and/or terrorist financing prevention measures set out in the AML law and cooperate with the FCIS. In addition, when the company is managed by a board, it must appoint a board member to organize the implementation of money laundering and/or terrorist financing prevention measures. The appointment of such employees and board members must be notified in writing to the FCIS no later than 7 working days after their appointment or replacement.

AML Officer appointed shall have the appropriate education, work experience, and skills necessary for implementation of risk-based approach inside the company. In addition, the person’s reputation has great importance here. After new law came into force, AML Officer appointed to crypto company shall be permanent tax resident of Lithuania and restriction for appointment to more than one VASP applies.

AML Officer performs the following functions in the company:

• Ensure that the AML/CFT, sanctions policies, procedures and internal control measures are adequate and proportionate, taking into account the characteristics of the company and the ML/TF, sanctions risks to which it is exposed;

• Develop and, when necessary, update the company’s internal policies related to AML/CTF and sanctions;

• Ensure that there is periodical reporting to the CEO on the activities carried out by the AML officer and that the CEO is provided with sufficiently comprehensive and timely information and data on ML/TF, Sanctions risks and AML/CFT, sanctions compliance, which is necessary to allow the CEO to carry out the role and functions entrusted to it;

Sanctions for failing to comply with the AML/CTF regulation

There’s many supervisory authorities (e.g. Bank of Lithuania, Chambers of Notaries, Auditors, etc.), which are responsible for imposing of fines to obliged entities, but for VASPs only FCIS may perform inspections, make orders for elimination of deficiencies and impose fines.

Lithuanian AML law establishes the following measures may be implemented for the purpose of ensuring fulfillment of regulation by VASP:

• Issue of mandatory instruction;

• Issue of warning;

• Imposition of fine;

• Temporary or permanent senior managers or other employees removal and/or revocation of their powers;

• Temporary or permanent suspension of the activities and/or prohibition for provision of services;

• Revocation of license issued.

From the responsibility’s point of view Lithuanian AML law defines gross and systematic violations, which have more significant importance and more strict regulatory measures. Amount of fine may be imposed depends on the company’s annual income and may grow up to 10% of the gross annual income received in the course of licensed activity.