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Crypto License in Lithuania

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Crypto Exchange & Wallet License in Lithuania

Crypto License in LithuaniaLithuania offers a friendly and regulated legal environment for virtual asset service (VASP) and crypto-asset service provider (CASP) companies. Our on-site Web3 specialised lawyers and crypto AML compliance professionals provide structured services for MiCA CASP licensing and on-going AML compliance solutions (e.g. MLRO and CCO outsourcing) support.

Lithuanian jurisdiction is a well known fintech hub in Europe with its forward looking crypto regulations. The Markets in Crypto-Assets (MiCA) licensing for CASPs is expected to open in early January 2025, with the transition period for VASPs until June 1st 2025. Depending on the project specifics we can support to choose the most optimal approach for a MiCA CASP license application, for example it is possible to structure the setup with a VASP license during Q1 2025 to take advantage of the MiCA grandfathering period. Our extensive experience since the birth of the European Union crypto legislation can be at your service if you like to work with professionals.

Quick summary

Exchange + Wallet Operator
Remote setup from 2 weeks
Price from 35.000 EUR
Min. 1 person structure for VASP
Local MLRO required
Pricing »
Contact us »

Lithuania has 2 types of crypto authorisations for VASP companies operating with virtual currencies:

Providers of a service of exchanging a virtual (crypto) currency against a fiat currency
Official activity authorisation covering services for exchanging fiat to crypto and crypto to fiat and crypto to crypto. Such activity registration enables to operate a crypto exchange in a regulated manner.

Providers of a virtual (crypto) currency wallet service
The virtual currency wallet service means a service in the framework of which keys are generated for customers or customers’ encrypted keys are kept, which can be used for the purpose of keeping, storing and transferring virtual currencies.

One company can hold both the crypto exchange and wallet operator authorizations. It is important to note that even though the word license is widely used to describe the underlying capabilities of the regulation, then per regulatory framework Lithuania provides an activity registration to operate as a regulated VASP and not a financial license per se. The activities are supervised by the Lithuanian Financial Crime Investigation Service (FCIS/FNTT). Our lawyers assist in applying for the crypto registration in Lithuania for providing crypto exchange and/or wallet services by preparing all required legal documentation and managing the process on your behalf fully remotely without travel needed. The regulator application review time is on average 2-4 weeks.

Key points for Lithuanian VASP Crypto License Company structure

In order to set up the crypto license in Lithuania to provide cryptocurrency exchange and/or wallet services a limited liability company (UAB) has to first be set up in Lithuania. The minimum share capital requirement is 1000 EUR as of 2023, but in order to authorize the company for VASP activities the capital injection required totals 125.000 EUR. The company setup can be carried out fully remotely with no visit required, it usually takes about 10 business days from the point we receive all required original documentation. The first step we take in the service engagement is analyzing the target shareholding and UBO structure, which enables us to provide the list of required documentation.

The minimum company structure requirement is currently 1 person who can act as the shareholder and the director (company signatory, can also be a non-resident, i.e. does not have to be Lithuanian). However, per regulations from November 2022 the VASP company must appoint a senior manager as money laundering reporting officer (MLRO). The MLRO must be a Lithuanian resident, further previous work experience and supportive documentation is needed. We recommend outsourcing a specialised service provider to fulfil AML compliance and associated reporting requirements, e.g. for a Money Laundering Reporting Officer (MLRO) and a Compliance Officer (CO). Subject to project review we can provide on-going support with local substance (e.g. physical office setup) and AML compliance personnel sourcing such as professional background Lithuanian resident MLRO and CO roles to take care of reporting and to meet the regulatory requirements.

It is also important to consider that a company holding the crypto license in Lithuania has to keep a detailed and up-to-date overview of all clients and transactions according to the AML/KYC regulations. The monitoring authority FCIS may make enquiries about the activities of the company, especially in regards to following the predefined AML/KYC policies. Our lawyers and AML compliance professionals can support with compiling the full set of legal and compliance documentation as the regulator may request to check and monitor the internal procedures.

General requirements

  • At least 1 shareholder (natural person or corporate entity). No restrictions to citizenship or residence. For optimal setup structure please consult our legal team.
  • 1 director (can be the same as the shareholder, but only a natural person). Foreign residents are allowed, there are no restrictions to citizenship or residence. For optimal setup structure please consult our legal team.
  • Money Laundering Reporting Officer (MLRO). From November 2022 requirement for local resident position with employment contract. 1 position per Lithuanian VASP company. Professional experience and fit-and-proper requirement. We can provide fully outsourced service solutions to meet the regulatory requirements.
  • Virtual office address accepted as company location. Beneficial owners’ details are disclosed to the authorities.

Taxation

  • Virtual currencies (e.g. Bitcoin and altcoins) exchange services are not subject to VAT.
  • Services invoiced (e.g. sales invoices) in virtual currencies are subject to regular VAT rules.
  • Corporate profits are taxed at 15% (CIT=15%). Small companies with fewer than ten employees and less than 300 000 EUR in gross annual revenues can benefit from reduced corporate tax rate of 0-5%.
  • Withholding tax (WHT) 15% is charged on gross dividends.

Banking advisory

Most VASP companies working in the crypto sphere, whether licensed in Lithuania or in another EU jurisdiction, take advantage of crypto friendly fintech banks working under the EMI license. We work with well known financial institutions to ensure the opening of a business bank account for your Lithuanian crypto licensed company. The speed and result will depend on your business model, background and co-operation during the KYC process.

Per our optional banking advisory service, after the company is set up, our banking team maps your needs (eg. SEPA, SWIFT, Instant SEPA etc.), volumes and financials etc. and reaches out to approx. 15-20 financial institutions supporting crypto and we inform you about soft pre-approvals available that could work for your needs. The service covers advisory, our know-how and work, the fees for opening accounts/KYC/etc will be paid directly to the banks. Most of our clients have been able to open an operational account in a few weeks. Please contact our consultants for a banking advisory quotation.

It is also important to note that currently traditional Lithuanian banks do not wish to work with crypto companies, thus mostly crypto-friendly EMI licensed fintech banks can be used, further we can suggest alternative banking options in Europe (Malta, Switzerland, Cyprus etc.). Please also note that for crypto companies higher level of AML/KYC principles are applied. We can support with appropriate banking solution consideration after we have an overview of the planned activities, shareholding structure and the company  financial forecasts to consider the best path forward.

Company formation

Our lawyers support whether with a new company incorporation or we provide an already prepared shelf company for a faster setup and license application submission. In our packages the company setup is already included. We also have availability for Lithuanian shelf companies with older registration dates and active VAT registrations. Usually the most time and cost efficient approach to register a company in Lithuania is to purchase a new shelf company, because the founding process can be a challenge to non-residents due to some requirements (e.g. share capital payment). In most cases, non-residents opt for a new tailor-made shelf company to avoid bureaucracy as we have already taken care of all requirements. However, we do assist with new incorporations on request. We will help you to choose the best approach according to your objectives. For more information refer to the Company Formation in Lithuania page »

Pricing for Crypto License in Lithuania

We support to obtain the crypto exchange and wallet operator registration in Lithuania to provide crypto exchange and wallet services, i.e. to operate as a VASP. The setup can be completed remotely without travel. Setting up a Lithuanian limited liability company (UAB) and applying for a crypto activity registration is made simple as our lawyers take care of the full legal procedures on your behalf and also provide on-going consultations. We also have availability for new and fully licensed companies without previous trading history for swift setup. For more information please contact us for a tailor-made offer for your project »

  • New UAB company in Lithuania
  • Remote setup without travel
  • Timeframe to start activities
  • Type of setup package
  • Registered share capital
  • Official authorisation
  • Your company name
  • All government and licensing fees
  • AML/KYC legal package
  • Virtual office address 1 year
  • Compliance services consultation
  • Bank account opened
  • Legal opinion by attorney-at-law
  • VASP GOLD PACKAGE New UAB shelf company package with new VASP license application; for non-residents (discontinued due to MiCA time-constraints)
  • discontinued
  • 2-3 months
  • New application
  • € 125.000 (capital injection required)
  • Crypto Exchange+Wallet
  • SEND ENQUIRY
  • VASP PLATINUM PACKAGE Activated VASP license company transfer for swift setup inc. bank account, no trading history (MiCA grandfathering period until June 2025)
  • € 35.000
  • 2 weeks EXPRESS
  • Ready-made VASP company transfer
  • € 125.000 (capital injection optional)
  • Crypto Exchange+Wallet
  •  
  •  
  • SEND ENQUIRY
  • CASP DIAMOND FULL MiCA UAB company incorporation package with new license application; conditions apply (project review required for MiCA CASP application)
  • per quote
  • Est. Q2/Q3 2025
  • New application
  • € 150.000 (capital injection required)
  • MiCA CASP CLASS 3
  • SEND ENQUIRY

* All orders are subject to our review and subject to our final confirmation; conditions may apply; recurring monthly service fees may apply in some cases. Notice: all pricing is indicative and is subject to our final confirmation upon receiving order details; indicative packages for one natural person participant. Prices shown excluding VAT, which is added; in some cases no VAT added. Discounts may be applied. We reserve the right to change our individual and package prices at any time without notice. Additional fees may apply in case of additional participants, corporate shareholder, translation services, legal analysis/opinion services, certified documents orders and more. Please contact us for a detailed offer specific to your project.

Legal Framework and Requirements for VASPs

The legal framework is governed by the Money Laundering and Terrorist Financing Prevention Act. We can prepare all policy documentation according to the legal framework and manage the process on your behalf for a successful application. The central list of authorized VASP companies database in Lithuania can be checked per specific company from the commercial registry.

Documentation

For review and preparation of the licensing project we will ask for the following documentation:

  • Valid copy of passport from each country of citizenship
  • Power of Attorney (PoA)
  • Description of planned business model and licensed activities
  • Resume (CV) listing employment and education background for all participants
  • Website address where services will be offered 
  • Non-criminal certificate from the registry of convictions (not older than 3 months) for shareholder(s), board member(s), ultimate beneficiary owner(s)  *

All listed documentation has to be certified by notary public and confirmed with an apostille, in English (or sworn English translation). In the first stage we will gather all information and provide step by step process overview according to your case.

Procedures

Our compliance team will prepare the full internal procedures documentation for the company to meet with the Anti Money Laundering (AML) and Know Your Customer (KYC) criteria established in the legal framework. Some parts of this include, for example:

Internal security measures
  • assessment and management of the risk of money laundering and terrorist financing;
  • collection and keeping of records;
  • performance of the notification obligation and notification of the management;
  • internal control rules for checking adherence thereto.
Rules of procedure
  • describing transactions of a lower risk level and establishing the appropriate requirements and procedure for carrying out such transactions;
  • describing transactions of a higher risk level, including risks arising from means of communication, computer network and other technological development, and establishing the appropriate requirements and procedures for carrying out and monitoring such transactions;
  • set out the rules of taking the due diligence measures;
  • set out the requirements and procedure for keeping the documents and records;
  • set out the requirements and procedure for application;
Instructions and guidelines
How to effectively identify whether or not the person is:
  • a politically exposed person;
  • a person whose place of residence is in a country where no sufficient measures for prevention of money laundering and terrorist financing have been taken;
  • a person with regard to whose activities there is prior suspicion that the person may be involved in money laundering or terrorist financing;
  • a person with regard to whom international sanctions are imposed;
  • a person with whom a transaction is carried out using telecommunications.

The legal framework is governed by the Money Laundering and Terrorist Financing Prevention Act, further by the Order No V-5, which provides the guidelines for the operators of crypto exchanges and custodian wallets.

AML Compliance

We can provide several approach possibilities in regards to substance for meeting regulatory requirements, e.g. we can support with setting up a local office and (out)sourcing highly qualified professionals of Chief Executive Officer (CEO), Chief Compliance Officer (CCO) and Money Laundering Reporting Officer (MLRO) roles, including support with on-going training, office and team management.

The duties of a Chief Compliance Officer (CCO) include, inter alia:

  • Main areas of work: internal controls; ensuring correct data keeping, reporting to the statistics agency, reporting to the data protection Agency, upkeep to any local regulatory deadlines to manage their compliance incl. AML, data breaches, fraud prevention, IT security and privacy procedures.

The duties of a Money Laundering Reporting Officer (MLRO) include, inter alia:

  • Main areas of work: supervision, monitoring and reporting functions, along with the communication with customers for EDD/CDD/ODD document collection and revision of any KYC/KYB/KYT reports, answering to the CEO/CCO.

We would also outline that the suggested local substance and employee count depends on your business model (inc. business plan) and trading volumes, we can provide our suggestions after completion of the preliminary analysis.

Revocation

The Money Laundering and Terrorist Financing Prevention Act sets forward cases in which the crypto license can be revoked.

  1. the undertaking repeatedly fails to follow the precepts of the supervisory authority;
  2. the undertaking has not commenced operation in the requested field of activity

Contact us for more information

We will provide a step by step overview with detailed timeframes and cost break-down after gathering the preliminary project information. Our track-record in setting up the crypto license in Lithuania for our clients is 100% as we follow a thorough checklist to confirm that all legal requirements are met. Please contact our legal department through the contact form below and we will get back to you with further information shortly.

    Contact details

    Please contact us to schedule a meeting with our crypto projects manager.

    Call our head office at +372.50.43.245

    E-mail us at lithuania@maxcorp.eu

    Lvovo g. 25, 09320 Vilnius, Lithuania