AML and KYC Procedures for Crypto Entities
Anti-money laundering and Know Your Customer procedures are the backbone of crypto operations in Lithuania. Introduced as overseeing mechanisms of economic security in the world of digital assets, these have a significant impact on how businesses and people trade in cryptocurrency exchange. To put it simply, compliance with AML and KYC is necessary, which is why lack of adherence to both directives determines if crypto-related businesses are eligible to operate.
In Lithuania, cryptocurrency regulation is a hallmark of fintech success. A sizable portion of emerging businesses in the finance sector dabble in digital assets such as NFTs, tokens, cryptocurrency, and more. With widespread use of virtual currency for purposes of trading and investing, a solid framework exists to support such activities.
To ensure the security and stability of the overall network, various authoritative institutes are involved. From the Bank of Lithuania to the Financial Crime Investigation Service (FCIS), each fulfills unique responsibilities.
The FCIS plays an essential role, overseeing cryptocurrency activities across the country. Not only does it closely observe how market players interact via digital assets but also keep tight control on adherence to established anti-money laundering and counter-terror financing laws.
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Legislation Changes Crypto Companies Must Know Of Increased minimum authorized capital
One might say that running a crypto business isn’t as easy as it used to be. Global governments, including Lithuania’s, are constantly updating regulations to match their economy’s evolving needs. It is no secret that a profitable business specializing in virtual currency is great for the economy; one that wastes time, money, and resources simply adds no value to the country’s GDP. Therefore, it makes sense why only businesses with high potential are allowed to dabble in crypto-related operations.
To protect customer interest, Lithuania amended the previous legislature regarding cryptocurrency business operations to increase the capital requirement for companies. This amendment went into effect at the beginning of 2023, whereby any business seeking a cryptocurrency license must have at least €125,000 worth of authorized capital. Interestingly enough, this wasn’t just for new companies but also existing ones operating with a license.
This move aligns with the European Union’s crackdown on entities involved in money laundering through cryptocurrency trade. It also boosts trust within the market by promoting overall stability. Another benefit of this is to keep the cryptocurrency business bubble competitive. By pushing companies to meet this criteria, those that succeed are able to attract more market share. Whereas, companies that fail to raise the required amount of minimum authorized capital are temporarily and permanently suspended.
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Anti-money laundering executives and permanent residency
Lithuania is home to a diverse range of entrepreneurs, not just from within its own local talent pool but across the globe. In fact, various cryptocurrency startups have foreign or international founders behind them. This is because the country offers an impressive regulatory framework that supports business growth.
Since the beginning, each cryptocurrency company was mandated to appoint an anti-money laundering compliance officer. This position could be filled by appropriate individuals in leadership roles at their designated organization. More importantly, this position could be filled by someone who lived abroad as well.
However, due to communication challenges arising among these companies and the regulatory bodies in Lithuania, the position of the AML officer is only to be filled by someone who is a local resident. The government stresses the importance of physical presence due to the nature of the business in question.
After this residency amendment, even existing licensed businesses reappointed their AML officers to remain compliant. Needless to say, any new company applying for a license must ensure that their AML officer is a Lithuanian local based within borders.
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Stringent KYC Requirements
Knowing your customer is critical to maintaining a clean and successful cryptocurrency business. Unfortunately, even well-intentioned virtual currency businesses have come under fire due to the illicit actions of their customer base in the past. This is exactly why all organizations dealing in digital assets take customer due diligence very seriously.
On the regulatory front, customer due diligence is a necessary requirement that demands strict compliance. With updated laws going into effect, all cryptocurrency businesses need to establish specific Know Your Customer methods for appropriate identity verification.
While requiring client details such as their contact, name, address, live photo verification, and ID documents was already there before 2023, new changes made the framework even more robust. As of early 2023, all transactions conducted on a crypto wallet or exchange platform require multi-factor authentication. For instance, in the case of chain transferring USDT from one wallet to the other, Kucoin users need to authenticate the transaction through a Google Authenticator code as well as the one sent to their email address.
Secondly, all users must submit their customer identity data every six months. Due to rising cases of identity fraud and clever loopholes used by crypto-criminals, businesses must ensure that the user accounts registered on their platforms are legitimate and traceable to the same person who signed up.
Another protocol that is rigorously followed by compliant fiat and virtual currency companies is the account suspension of anonymous accounts. All individuals dabbling in cryptocurrency trades should be verifiable and traceable, which is why anonymous accounts are completely banned today.
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Monthly Disclosures by Cryptocurrency Companies
Financial crime exists on the individual as well as the business level. Verily, regulations seek to control and prevent both types. One of the reasons Lithuania is praised for its crypto-friendly landscape is that it provides market transparency. Due to evolving regulations and innovative changes made to how businesses are allowed to operate in the crypto niche, company-market participant-government transparency is present.
Naturally, there is always room for improvement which is why updates to law now require that all companies dealing in virtual currency disclose their filings each month. This applies to wallet and exchange providers alike. Simply put, it is mandatory to share trading activity with the state.
The Financial Crime Investigation Service requires that these companies submit information on their total clientele (number of active customers), number of new customers acquired, and the aggregate volume of virtual currency transactions. To top it off, virtual currency startups should report any transaction that is suspected to be illicit or even slightly shady.
Another major change introduced to legislation focuses on protecting consumer rights and interests. The Lithuanian government has shown time and time again that it grants great autonomy to its citizens and local businesses within bounds of compliance. Therefore, a Registry Center was established to showcase a list of licensed cryptocurrency operators.
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AML and KYC Procedures in Lithuania
Lithuania, as part of the European Union, follows all laws set by the EU. This includes regulations related to cryptocurrency. The EU is very serious about preventing money laundering through digital money. To make sure fraud and illegal financing don’t happen, Lithuania has to follow strict rules from the EU. With the Anti Money Laundering and Counter Terror Financing rules, fintech companies and digital asset exchanges need to meet certain requirements. They have to be eligible to sign up, have a certain amount of money as a start, and more. This helps keep things safe and fair for everyone involved.
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Essential Aspects of AML and KYC Compliance Procedures
Customer Verification and Due Diligence
Lithuanian financial institutes must make sure their customers are who they say they are. Conducting customer verification and due diligence is a crucial part of running a successful fintech. You need to ensure that users using your service or platform can be verified and that you have enough information about them. Especially when large amounts of money are involved, businesses are even told to do background checks on their customers.
Part of this process involves identifying and verifying the identities of customers who are signing up for crypto services. You also need to check that the personal information they provide matches their official identity documents. Additionally, it’s important to validate the addresses or locations they claim to be from. These steps help ensure the safety and security of your platform and the integrity of your services.
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Transaction Monitoring and Maintenance of Client Records
In Lithuania’s financial system today, it’s easier to catch financial fraud as it happens. When there’s suspicion, cryptocurrency companies should be able to check client records easily. That’s why they are required to keep records of their clients’ profiles, transactions, and more. Additionally, compliance demands that all customer records be updated over time and relevant data always be available in time for upcoming audits.
These companies also need to monitor the activities being conducted through their platform. This is because if criminal activity happens, the exchanges being used might also become implicated. Part of their job is to keep an eye on customer transactions all the time. They also need to check for any behavior that seems suspicious and assess the risks connected to a customer or transaction. It’s all about keeping things safe and fair for everyone involved.
Reporting Suspicious Activity
While protecting client interest is critical, all fintechs are ordained by law to immediately report suspicious activity. Whether it’s unusual transactions or something else, the Financial Crime Investigation Service must be informed. One key element of Lithuania’s success at curbing financial crime within its borders is that it brings financial players on board to keep the system clean. While there is no select reward for reporting incidents of criminal activity, it helps build trust and compliance with the government.
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The Pros of Lithuania’s Cryptocurrency Regulatory Framework
No Local Office Required
Unlike other business setups in industries that demand a physical office presence, Lithuania’s rules concerning cryptocurrency ventures are quite flexible. The government understands that the modern age is driven by remote innovation which is why entrepreneurs can start their business without incurring hefty overhead costs. That being said, all cryptocurrency businesses must appoint a local resident within the leadership role of the AML executive.
Convenient Business Reporting
While the Lithuanian government does not tolerate lack of compliance, it maintains friendly relations with AML/CTF compliant cryptocurrency businesses. As a fintech or related startup, reporting to the government is made easy through an established route. The Lithuanian government makes it clear the ‘what,’ ‘when,’ and ‘how’ of operating a business that adheres to mandated rules.
Technology-First Approach
Unlike nations where new-age technology is approached with fear and hesitance, Lithuania has a proactive approach to integrate innovation. The government is known for its forward-looking perspective on onboarding new trends in technology and finding ways to regulate it. Therefore, setting up a business in Lithuania or even participating in the cryptocurrency market as a consumer is encouraged.
Fast Business Approval
One of the leading reasons many foreigners have set up virtual currency ventures in Lithuania is because of the country’s efficient approval procedure. If you’re also looking to start your business, know that you likely won’t experience delays in approval. That is, as long as you’re doing everything right from your end. An incomplete or error-filled application is bound to get rejected and cause unnecessary delay in business registration.
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How to Start a Crypto Venture in Lithuania?
Starting a cryptocurrency business in Lithuania opens doors of limitless opportunity. For many who are eager to start their company but haven’t yet researched how to, the concept is shrouded in mystery. In reality, however, setting up a compliant virtual currency business in the European country is all about following a series of steps. Lithuania provides an easy-to-follow guide for cryptocurrency service providers to operate within local borders.
Aside from a robust regulatory framework that reduces financial fraud and crime, entrepreneurs have access to industry knowledge and market experience. You can connect with specialists and leading entrepreneurs to scale your own business growth, get advice, and make informed decisions.
Rest assured, even newbie entrepreneurs have immersive chances to learn as they grow. But before that, you must have a general idea of what it takes to start your very own crypto venture in Lithuania.
First and foremost, you must incorporate your business in Lithuania. Whether you’re thinking of launching a crypto exchange, wallet service, NFT venture, or P2P platform for fiat, your business should officially incorporate as one of these:, private limited liability company, or public limited liability company. Depending on the type of license you plan to apply for, choosing between the aforementioned four types can vary. Down the line, each will have different pros and cons, which is why it is essential to review your decision based on informed options.
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Similarly, compliance regarding minimum authorized capital, industry standards, and leadership stipulations is different. Once incorporation is out of the way, entrepreneurs need to focus on leadership hierarchy. While Lithuania’s regulations do not interfere with how a business manages its employees, certain prerequisites are very important. For one, all persons appointed to the role of directors should have clean and verifiable backgrounds. At least one of the total directors should be based locally within national borders. In the same way, one of the shareholders also needs to be a Lithuanian local.
Fortunately, businesses aren’t required to have an on-ground office in Lithuania itself. While a designated business address is a must, you and most of your team can work virtually from anywhere across the globe. This will eventually be followed by meeting the minimum authorized capital requirements that apply to your specific case before applying for a relevant authorization with the Companies House.
Finally, to be able to start operating as a player within the financial industry, you need to get permission from key Lithuanian regulators. This is where the process of registration comes in, which is fairly simple. As an incorporated business, the FCIS and Bank of Lithuania will require documents and data such as your business plan, license and certification proofs, memorandum of association, proof of capital contribution as well as proof of registered address. Rest assured, if your business fits regulatory criteria, approvals will come quickly.
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The Verdict
Lithuania, also known as an emerging hub of innovation, is known for its leading role as a crypto-friendly nation in Europe. With a robust foundation of rules that encourage digital diversity within the bubble of digital assets and cryptocurrency, it allows businesses and investors to thrive. Naturally, as digital currency becomes more widespread across the globe, Lithuania continues to strengthen its compliance landscape through strong AML and KYC procedures for crypto entities across the board.
Current Framework: Lithuanian Financial Institutions and Regulations
Lithuania continues to make strides in the fintech bubble as increasingly more people and governments set their eyes on its thriving financial landscape. According to Statista, the market for digital assets in Lithuania is forecasted to grow by 2.79% in the years 2024 to 2028 alone. This isn’t just the result of eager fintech ventures setting up their roots in the country. In fact, Lithuania is able to record rapid economic growth due to its welcoming regulatory framework that governs how business entities and entrepreneurs operate.
A complete overview of the existing financial regulations in the country reveals insight into various aspects. From strict crypto licensing requirements to evolving banking legislation, it encompasses everything. While Lithuanian law might seem a bit too complex to the average layman, it’s actually not that difficult to understand. For someone looking forward to starting their venture, this article helps navigate how financial organizations operate in the virtual currency world of Lithuania.
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Key Regulatory Entities in Lithuania
European Union
The European Union influences the laws active within Lithuania. Since the country is a member firm of the EU, it must abide by all regulations laid down by the entity. The influence of the EU extends to all aspects of Lithuanian law, in particular, cryptocurrency.
Seeing as how the European Union is especially stringent when it comes to money laundering through digital assets, Lithuania adheres to a list of tight legislative directives to ensure that fraud, laundering, and terror financing don’t go unnoticed. With the Anti Money Laundering regulations in effect, fintechs and exchanges dealing in digital assets such as cryptocurrency and NFTs must fulfill certain criteria. This involves being eligible to register, having a set amount of minimum capital and more.
On the other hand, the European Union also takes issues of data privacy very seriously. Due to various lawsuits against big names in the past, constant updates are introduced to the general Data Protection Regulations. While GDPR laws apply to all sectors of the economy in Lithuania, they are particularly essential for companies in the financial sector. Since digital asset-related businesses rely on identity-verification processes like Know Your Customer, they must also ensure that this user information is protected at all costs.
Bank of Lithuania
The Bank of Lithuania is a critical institution that supervises various financial functions in the country. It has autonomous authority overseeing the entirety of the financial system as the central bank. The BoL has various responsibilities. Not only does it regulate other banks in the country, but it also oversees the operations of payment service providers as well as electronic money institutions.
However, this is just the tip of the iceberg. The Bank of Lithuania is an essential decision-maker when it comes to Lithuanian monetary policy. Therefore, it directly determines the stability of the economy by implementing the right measures to boost growth. Additionally, the Bank of Lithuania enjoys the sole right to issue the national currency. This is in part how it controls the cash supply throughout the state to ensure that the economy remains stable with enough money in circulation for the public and various institutes.
In recent years, due to the onboarding of digital assets as a means of exchange, the bank has also diverted greater attention toward the efficiency of payment systems. This not only promotes the development of innovative payment methods but also ensures the reliability of transactions conducted within and beyond national borders. Overall, the Bank of Lithuania plays a huge role in terms of financial market development – it continues to create more avenues for market transparency to boost innovative growth.
Financial Crime Investigation Service
The Financial Crime Investigation Service (FCIS) was set up in 1997, primarily to oversee issues of tax evasion. Five years down the line, the institution was expanded and renamed to FCIS to crack down on all crimes of financial nature in Lithuania. Due to the EU’s looming influence, this department collaborates with Europe’s Anti-Fraud Office over money laundering and terror financing cases.
At present, the Bank of Lithuania joins hands with the Financial Crime Investigation Service to ensure that businesses registered within the country abide by established anti-money laundering and counter-terror financing laws. Failure to do so not only results in hefty penalties but also legal action.
Key Financial Regulations in Lithuania: AML and CTF
While Lithuania is known across the globe for being crypto-friendly, such is not the case for a lot more nations. This is due to various reasons, the topmost one being that cryptocurrency as well as digital financial assets aren’t easy to regulate. Moreover, lack of understanding of tokens, NFTs, coins and more requires adoption of new-age knowledge-based mechanisms which most governments, especially in the developing world, are ill-equipped to do so.
Contrarily, countries that have embraced the use and trade of cryptocurrency within their borders are constantly updating their methods of compliance. This isn’t just done to stay ahead of the game but a necessity in the modern era where financial criminals keep finding new ways to wreak havoc. Therefore, innovative mechanisms of legislation are necessary to keep the financial system stable and secure from those with negative ulterior motives.
Lithuania ensures that businesses, exchanges and other entities dealing in digital assets maintain compliance with the law through two key regulations, namely anti-money laundering (AML) and counter-terror financing (CTF).
Both regulatory frameworks are designed to achieve multifaceted goals. As a government adept at cracking down on financial crime, AML and CTF enable supervisory institutions to identify areas of suspicious activity, prevent any such activity from having damaging consequences, and report suspicious actions taken in real-time.
To understand this, it is essential to understand how money laundering and terrorist financing work. For instance, let’s take the example of a common illegal activity such as drug trafficking. Criminals moving flagged substances in and out of the country are often caught when large amounts of money are flagged by banks and financial institutes. Due to the rise of exchanges like Binance, Kucoin and Coinbase, carrying out drug transactions on decentralized networks has become incredibly easy.
The most notorious way to move drugs today is to send money to the receiver in small amounts over a decentralized network. Bear in mind that the communication associated with drug deals usually happens via the dark web, which is extremely difficult to detect, thus making the entire process complex and nearly undetectable.
However, with AML legislation in place, organizations are less likely to accidentally commit actions that may be deemed suspicious. This has two-fold benefits whereby authentic companies partaking in legal dealings are able to avoid getting flagged whereas entities participating in illegal activities become easier to detect, prevent, and punish.
What is Know Your Customer and Why is it so important?
Know Your Customer is a process that institutes in Lithuania are required by law to implement. In simple words, KYC involves the collection of necessary personal information from an individual looking to access a new service. For instance, as someone eager to trade cryptocurrency tokens on Binance, you must first create an account with your name and contact details. But that’s not all, KYC also demands verifiable information that proves identity. This is why signing up for digital asset exchanges involves submitting a scanned copy of your identification documents (national identification card, passport, driver’s license) and a live photo that matches the picture on your provided ID information. All of this is essential to start conducting financial transactions, no matter how big or small.
Why are Fintechs required to follow KYC regulations in Lithuania?
Risk Management
Financial entities, be it exchanges, P2P lending platforms, small banks, or crypto exchanges, all have to minimize risk to their business through several measures. Through KYC, a large part of that risk derived from clients is reduced. Since Know Your Customer mechanisms prevent identity theft and financial fraud, fintechs enjoy a reduced number of unauthorized transactions. This not only protects from financial liability in court but also results in lower losses recorded due to their clients’ actions.
Building credibility
Regulators in Lithuania make clear time and time again that fintechs that play their cards right will find it easy to succeed. Being in the good books of national regulators is essential to climbing the ranks in the financial sector. Over the years, companies with a robust KYC mechanism have gained the trust of various parties including clients, external partners, and even governments.
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Compliance Management
All companies, including Fintech startups and giants, must comply with the established format of KYC processes. This is done to mitigate cases of terror financing, internet fraud, money laundering, as well as monetary exploitation and solicitation. Not only are fintechs not complying with KYC eventually revoked of their licenses, but repeat offenses may also lead to regulatory penalties.
Regulatory Obligations of Fintechs in Lithuania
As an exchange operator, a crypto wallet service provider, or business in this category, here are the crucial obligations you must follow.
Customer verification and due diligence
As a financial institute, your responsibility isn’t simply limited to the service you provide. Conducting customer due diligence is an integral part of running a successful fintech. Not only do you need to prove that users using your service or platform are verifiable but also have adequate information on their personal profile. In cases where large amounts of financial transfers are involved, businesses are even instructed to conduct background checks on the customers they are working with.
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Transaction monitoring and maintenance of client records
While the financial system in Lithuania today does make it easier to detect financial fraud in real time, client records are thoroughly inspected in cases of suspicion. This is exactly why all types of fintechs are required to maintain records of their clients’ profiles, transactions, and more. To top it off, you must also monitor the activities being conducted through your service or platform. This is simply because in the incident of criminal activity, the exchanges being used might also become implicated.
Immediate reporting of suspicious activity
While protecting client interest is critical, all fintechs are ordained by law to immediately report suspicious activity. Whether it’s unusual transactions or something else, the Financial Crime Investigation Service must be informed. One key element of Lithuania’s success at curbing financial crime within its borders is that it brings financial players on board to keep the system clean. While there is no select reward for reporting incidents of criminal activity, it helps build trust and compliance with the government.
What are screening and compliance sanctions within the Lithuanian cryptocurrency bubble?
Just as fintechs are required to follow legislation established by the European Union, they are also supposed to follow the rules laid down by international sanctions. In particular, the United Nations’ sanctions screening and compliance are critical. A series of measures and policies are defined to prevent human rights violations, terror financing, money laundering, and more.
Inability to follow these sanctions can lead to a severe reduction in investment opportunities. In fact, banks, in particular, must stay abreast of the US Office of Foreign Assets Control List to know which businesses are off-limits. This is just one example. Various other sanctions lists exist and require a fintech’s constant attention.
Adherence to the regulatory framework is vital. Through quality of service and consistent legislative compliance, businesses in Lithuania can thrive further. An essential milestone for many companies specializing in digital assets is to get licensed.
Common Types of Lithuanian Fintech licenses
All fintechs must acquire a legitimate license issued by the Bank of Lithuania before they are able to start serving customers. This is where it gets tricky. Emerging entrepreneurs setting up their businesses in Lithuania need to educate themselves over the type of license suited to their company. In the context of digital assets, there are two main types of crypto licenses you should know about.
Lithuania Cryptocurrency Exchange License
Firms eager to set up a virtual currency trading system in the nation can secure a cryptocurrency exchange license. This license grants them legal authority to kickstart operations, including crypto exchange to earn commissions and other associated tasks. However, fulfilling all anti-money laundering (AML) and know-your-customer (KYC) criteria is vital to qualify for any cryptocurrency license.
Electronic Money License
Enterprises aiming to offer e-money services to their clientele must seek an Electronic Money license (EMI). Upon approval, this license empowers companies to deliver wallet services to customers. EMI licenses are solely suitable for well-funded companies, as they require a minimum share capital of €350,000. This is coupled with the implementation of robust and verifiable risk management frameworks within the business.
Overall, the EMI license provides substantial flexibility to holders as businesses can extend their services across the entire European Economic Area, rather than being confined to Lithuania alone.
Payment Institution License
Businesses with plans to provide transaction services involving cryptocurrencies must obtain a Payment Services license. With this license, companies can offer comprehensive payment solutions, including establishing platforms for currency exchange, direct debits, crypto to fiat transactions, and more.
Similar to the EMI license, holding a Payment Institution license permits legal operation throughout the European Economic Area. However, the key difference lies in the minimum capital requirement. Applicant businesses must maintain a capital of at least €125,000 to qualify for this license.
How do fintechs obtain licensing in Lithuania?
The prospect of becoming licensed in Lithuania isn’t complex, but it does involve a few steps. You must abide by a series of regulatory requirements determined by the type of license needed. That being said, the general process is relatively the same whereby fintechs must:
Submit application
The Bank of Lithuania approves all and any businesses in the fintech sector before they become officially recognized. Verily, you must submit a detailed application of your startup to this institute. By rule of thumb, a successful application includes clear information regarding the business model, human capital and hierarchy, funding/capital sourcing, financial forecasts, client profile identification, operative capabilities, and risk management.
Prove compliance
As mentioned above, compliance is key. As a new business seeking a license, you must provide tangible proof that your fintech is and will continue to comply with all regulations. This includes Anti Money Laundering, Counter Terror Financing, and Know Your Customer directives.
Maintain compliance
Licensing in Lithuania isn’t a one-time thing. Fintechs that fail to maintain regulatory compliance cannot, in good faith, keep operating with their license intact. Therefore, ongoing compliance is necessary to remain relevant in the financial industry. This involves everything from having robust risk management structures in place to reporting any suspicious activity to the FCIS.
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