Crypto Exchange License in Lithuania

Crypto Exchange & Wallet License in Lithuania

Crypto License in LithuaniaLithuania offers a friendly and regulated legal environment for crypto exchange and crypto wallet services provider companies, with clear regulations in place since 2020. Our onsite lawyers provide professional solutions for crypto exchange and wallet licenses setup. The company and license setup is possible fully remotely, with no travel required.

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 come at lower on-going cost as there is no specific requirement for onsite personnel. Our extensive experience both in Estonia and Lithuania can be at your disposal if you like to work with professionals.

Quick summary

Exchange + Wallet License
Remote setup from 2 weeks
Price from 8.500 EUR
Min. 1 person structure
No local presence needed

Lithuania has 2 types of crypto licenses for virtual currency operations:

Providers of a service of exchanging a virtual (crypto) currency against a fiat currency
Official activity license covering services for exchanging fiat to crypto and crypto to fiat and crypto to crypto. Such activity license 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.

The crypto licenses are supervised by the Lithuanian Financial Crime Investigation Service (FCIS). Our lawyers assist in applying for the crypto licenses in Lithuania for providing crypto exchange and/or wallet services by preparing all required legal compliance documentation and managing the process on your behalf fully remotely without travel needed. One company can hold both licenses. The regulator application review time is on average 1 month.

Key points for Lithuanian Crypto License Company structure

To apply for the Lithuanian crypto license 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 2500 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 minimum company structure requirement is currently 1 person who can act as the shareholder, director and compliance officer all in one. However, for the compliance officer position previous work experience and supportive documentation is needed. We recommend out-sourcing a 3rd party service provider to fulfill AML and KYC requirements. The recommended setup structure is to include at 2 least board members while the compliance officer should have previous professional work experience, Lithuanian residency is not required per se. Subject to project review we can provide on-going support with certified accounting, local substance and compliance services.

A licensed company 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 will support in compiling the full set of legal and compliance documentation as the regulator may request to check and monitor the internal procedures.

  • At least 1 shareholder (private person or corporate entity). No restrictions to citizenship or residence. For optimal setup structure please consult our legal team.
  • At least 1 management board member (can be same as shareholder). No restrictions to citizenship or residence. Additional board member(s) foreign residents are allowed, no restrictions to citizenship or residence.
  • AML compliance officer (can be same as board member). No restrictions to citizenship or residence. Professional experience and fit-and-proper requirement.
  • Local office setup needed. Virtual office accepted.
  • Beneficial owners’ details are disclosed to the authorities.
  • 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.

Most companies working in the crypto sphere, whether licensed in Lithuania or Estonia, take advantage of crypto friendly fintech banks working under the EMI license. We work with several traditional and fintech banks to ensure the opening of a business bank account for your Lithuanian company. The end-result will depend on your business model, background and co-operation during the KYC process. Most of our clients have been able to open an operational account in a few weeks, it just may happen that applications to several banks have to be submitted.

It is important to note that currently traditional Lithuanian banks may prove to be difficult to work with regarding non-residents and especially crypto companies, but Lithuanian based fintech banks do not have such challenges, further we can suggest alternative banking options in Europe. 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 full overview of the planned activities and financial forecasts to consider the best path forward.

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. We also have availability for Lithuanian shelf companies with older registration dates and active VAT registrations. We can provide you with a turnkey solution with all the support services. 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 deposit). 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 provide efficient solutions for crypto exchange and wallet licenses setup. Possibility for full remote setup with no travel. Setting up a Lithuanian limited liability company and applying for a FCIS monitored crypto activity license is made simple as our lawyers take care of the full legal procedures on your behalf. We also have availability for new and fully licensed shelf companies for swift setup. For more information please contact us for a tailored offer for your project >>

  • New UAB company in Lithuania
  • Remote setup without travel
  • Timeframe to start activities
  • Type of setup package
  • Registered share capital
  • FCIS crypto license type
  • All government and licensing fees
  • AML/KYC legal package
  • Virtual registered office 1 year
  • Compliance services consultation
  • Bank account opened
  • SILVER PACKAGE UAB company incorporation package with new license application
  • € 8.500
  • 2-3 months
  • New license application
  • € 2.500 (deposit needed)
  • Crypto Exchange+Wallet
  • GOLD PACKAGE New UAB shelf company package with new license application
  • € 12.000
  • 1.5-2 months
  • New license application
  • € 2.500 (pre-registered)
  • Crypto Exchange+Wallet
  • PLATINUM PACKAGE Activated license UAB shelf company transfer for swift setup inc. bank account
  • € 25.000
  • 2-3 weeks EXPRESS
  • Activated license company transfer
  • € 2.500 (pre-registered)
  • Crypto Exchange+Wallet

* 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 in euros and is subject to our final confirmation upon receiving order details; indicative packages for one natural person participant. Prices shown excluding VAT; 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 corporate shareholder, translation services, legal analysis services 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, specifically the Order No V-5 from January 2020, which provides regulation for the operators of crypto exchanges and custodian wallets (link). We can prepare all policy documentation according to the legal framework and manage the process with the FCIS on basis of a Power of Attorney (PoA).

For reviewing and preparing the license application 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 
  • Certificate of non-criminal record from the registry of convictions (not older than 3 months) for shareholder(s), board member(s), ultimate beneficiary owner(s) and compliance officer *

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

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 or seat 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 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 requirements set by the FCIS for a Compliance Officer (CO) include:

  • only a person who has the education, professional suitability, the abilities, personal qualities, experience and impeccable 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.

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 licensed companies 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

    E-mail us at lithuania@maxcorp.eu

    Lvovo g. 25, 09320 Vilnius, Lithuania