Crypto License in Lithuania

Crypto Exchange & Wallet License in Lithuania

Lithuania offers a friendly and regulated legal environment for virtual asset service provider (VASP) companies, with clear regulations in place since January 2020. Our on-site lawyers and AML compliance professionals provide structured solutions for crypto exchange and wallet authorisations setup. The VASP company setup can be completed fully remotely, without travel.

Vilnius, the capital of Lithuania, is a well known fintech capital in Europe and is also receiving more attention for its regulations for crypto exchange services licensing. In comparison to its neighbouring destination Estonia, Lithuanian regulations can be viewed as more flexible in terms of the setup and entry to market speed, while also having lower on-going operational costs. Our extensive experience since the birth of the European Union crypto legislation can be at your disposal if you like to work with professionals.

Quick summary

Exchange + Wallet Operator

Remote setup from 2 weeks

Price from 10.000 EUR

Min. 1 person structure

Local MLRO required

Pricing »

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 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 shareholders 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 fulfill AML compliance and associated reporting requirements, e.g. for a Money Laundering Compliance Officer (MLCO) and a Money Laundering Reporting Officer (MLRO). Subject to project review we can provide on-going support with local substance and AML compliance outsourcing services such as professional background Lithuanian resident MLCO and MLRO positions 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 in Lithuania
Legal opinion by attorney-at-law

SILVER PACKAGE UAB company incorporation package with new license application; only for Lithuanian residents
€ 10.000
2-3 months
New application
€ 125.000 (capital injection required)
Crypto Exchange+Wallet
SEND ENQUIRY

GOLD PACKAGE New UAB shelf company package with new license application; for non-residents
€ 20.000
2-3 months
New application
€ 125.000 (capital injection required)
Crypto Exchange+Wallet
SEND ENQUIRY

PLATINUM PACKAGE Activated license UAB company transfer for swift setup inc. bank account, no trading history
€ 30.000
2 weeks EXPRESS
New VASP authorized company transfer
€ 125.000 (capital injection optional)
Crypto Exchange+Wallet
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

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. The updated AML law amendments from November 2022 can be found here.

Compliance officer

We can provide several options for a solution in regards to AML compliance support, we can further support with professional AML reporting officer out-sourcing to take care of the company reporting requirements.

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

organisation of the collection and analysis of information referring to unusual transactions or transactions or circumstances suspected of money laundering or terrorist financing, which have become evident in the activities of the obliged entity;
reporting to the FCIS in the event of suspicion of money laundering or terrorist financing;
periodic submission of written statements on compliance with the requirements to the management board;
performance of other duties and obligations related to compliance with the requirements.

The overall requirements set for a Compliance Officer (CO) include:

only a person who has the education, professional suitability, the abilities, personal qualities, experience and reputation required for performance of the duties of a CO may be appointed as a CO;
the company must organize specialized training on money laundering and / or terrorist financing prevention measures for their employees, especially those who work directly with customers and their transactions.

Revocation

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

the undertaking repeatedly fails to follow the precepts of the supervisory authority;
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 be connected with our crypto projects manager or to schedule a meeting.

Call our head office at +372.50.43.245

WhatsApp message us

E-mail us at lithuania@maxcorp.eu

Lvovo g. 25, 09320 Vilnius, Lithuania

Licensed Service Provider
for Company Formations and
Corporate Services, since 1998