CASP License in Lithuania

Obtaining a Lithuania CASP license is included in the list of mandatory requirements for lawful operation of any crypto service provider in this jurisdiction. Why? The point is that such licensing helps companies comply with the MiCA standards – the Markets in Crypto-Assets Regulation – which was adopted in the EU in 2023.

In this material, we will discuss the key aspects of CASP licensing in Lithuania: we will talk about who needs it, the specifics of the procedure, the requirements for licensees, and much more.

What is a CASP License in Lithuania?

A Lithuanian CASP license implies the registration of a crypto asset service provider with the FCIS – Financial Crime Investigation Service.

In other words, it is effectively the registration of a provider in accordance with Lithuanian anti-money laundering (AML) laws, which allows for the provision of services in the field of virtual assets on a legal basis.

At the moment, the country is in a transitional stage from local rules for the operation of CASPs to the unified MiCA regulation for the entire European Union. According to the latest data, this transition period will last until 01.06.2026. Until it ends, companies are required to fully adapt their processes to the new requirements. And the Lithuanian CASP license allows them to do this in the best possible way.

Why Choose Lithuania for CASP Licensing?

Lithuania has long become a jurisdiction popular among providers of services in the field of cryptocurrencies and other virtual assets. The reason lies in the fact that obtaining a crypto license in Lithuania opens up a number of advantages for business owners of this type:

1. Favorable regulatory environment. In Lithuania, a company can register as a CASP in just 1–2 months. This is much faster than in a number of other countries. In addition, the AML compliance procedures are relatively clear, and the authorities are friendly toward digital currencies.

1. EU membership. First, Lithuania is one of the countries where MiCA applies. This means strict, transparent regulation of businesses related to virtual assets. Second, many companies use the country as a launching pad for entering the broader European market.

1. Crypto-friendly business environment. Lithuania has a well-developed technological ecosystem, which promotes the emergence of startups. There is also access to a qualified English-speaking workforce, and operational costs (compared to Western Europe) are relatively low.

1. Extensive opportunities for banking services and partnerships. Many crypto-friendly banks and payment systems are ready to serve CASPs in Lithuania. Also, licensing in this country helps build trust among partners, investors, and clients.

1. A first step toward MiCA licensing. Since the country is in a transitional period between local licensing and pan-European regulation of CASP activities, companies have time to prepare for this transformation. They have the opportunity to build infrastructure, adapt their policies and procedures to operate within the law.

Would you like to experience all these advantages for your business? Contact professional lawyers to make the CASP licensing process fast and simple.

Who Needs to Obtain a Lithuanian CASP Licence

You need to obtain a CASP License in Lithuania if your company provides the following services:

• Cryptocurrency exchange. This may include the exchange of one virtual currency for another (for example, BTC to ETH) or cryptocurrency for fiat money (for example, BTC to Euro).

• Wallet storage. This includes the company storing private keys on behalf of clients or managing clients’ crypto assets/wallets.

• Consulting services in the field of virtual assets. For example, advising on regulatory compliance, strategic or technical consulting, and so on.

• Cryptocurrency transfers. Such transactions consist of transferring crypto assets from one wallet to another. They may be carried out between individual users or cryptocurrency exchanges.

• Trading of virtual assets. If you own an operating trading platform where users can buy/sell crypto assets, your activity is also subject to licensing.

• Other services (on a case-by-case basis). This may include token issuance, if the token qualifies as a virtual asset. Some DeFi or NFT platforms may also be subject to licensing if they perform storage or exchange functions for crypto assets.

Are you unsure whether you need a CASP License in Lithuania? Consult a lawyer. Experts will conduct a detailed analysis of your business and provide a clear answer regarding the need for licensing.

Lithuanian CASP License Regulators

Two principal regulatory agencies in Lithuania oversee CASP activities:

• Bank of Lithuania (BoL). Its responsibilities include:

• making decisions on licensing;
• monitoring companies for compliance with requirements;
• imposing fines or revoking licenses in case of violations.

• Financial Crime Investigation Service (FCIS). This body is responsible for identifying and investigating violations related to AML/CTF compliance.

Specific Requirements for Obtaining a CASP License in Lithuania

To obtain a CASP License in Lithuania, you must fulfill certain conditions:

1. Establish a legal entity in this jurisdiction. This could be either a public limited liability company (AB) or a private limited liability company (UAB).

• Submit the required documents. To obtain a license, you must prepare and submit the following package of documents to the BoL:

• an application for obtaining a Lithuania CASP license (official form);
• corporate papers such as the Articles of Association and registration confirmation;
• information about the management – directors, shareholders, and the appointed Anti-Money Laundering Reporting Officer (MLRO). You must provide identity documents and criminal record certificates.
• AML procedures. Prepare and submit AML/CFT policies to the regulator in advance.
• financial statements confirming compliance with initial capital requirements.

• Ensure reliable security measures. A company operating in the virtual asset sector must guarantee the protection of clients’ funds, ensure an organizational structure with high-quality service and sufficient throughput capacity.

Arrange a guarantee document/insurance policy to cover potential client claims.

1. Implement effective risk management procedures. CASPs are required to identify and evaluate potential risks and consistently implement measures to mitigate them.

• Open a corporate bank account. This step is necessary to deposit the share capital. However, that’s not all. With this account, you can also demonstrate your financial stability and operational legitimacy.

Moreover, a bank account is necessary for carrying out daily operations (e.g., accepting client payments).

CASP License Requirements in Lithuania

In addition to the points mentioned earlier, CASPs in Lithuania are obligated to meet capital requirements, management criteria, and several other rules.

Minimum Capital Requirements

A CASP in Lithuania must contribute minimum capital. The amount depends on the type of CASP activity:

• Class 1: €50,000
• Class 2: €125,000
• Class 3: €150,000

Local Office

The provider must ensure a local presence, meaning the company must have a local office in Lithuania.

Requirements for the Company’s Management

Members of the board of directors and executives holding key positions must undergo a fit and proper assessment. This is required so that the regulator can be assured of their honesty and competence.

Also, at least one board member must be an EU resident.

Internal AML/KYC Procedures

The CASP must develop a comprehensive policy for combating money laundering and terrorist financing.

A mandatory requirement is the appointment of an AML Reporting Officer. The person has to be a Lithuanian resident.

The CASP is also obligated to monitor transactions and report suspicious activities to the FCIS.

Lithuanian Regulations on Transfer of Funds (TFR)

The Transfer of Funds Regulation (TFR) is enforced on CASPs in Lithuania. It requires full traceability of crypto asset transactions. This regulation is fully aligned with the broader EU efforts to combat money laundering and terrorist financing.

Compliance with the rules established by the TFR is a mandatory requirement for CASPs in Lithuania. According to this document, providers must:

• Collect and transmit to the FCIS information about the sender and recipient of crypto assets. This includes their names, wallet numbers, and legal entity identifiers (if applicable).
• Confirm ownership of self-hosted wallets. This rule applies if the transfer amount exceeds €1,000.
• Implement Enhanced Due Diligence (EDD) when working with counterparties from third countries.
• Keep transaction records and store them for at least five years. The purpose is to facilitate audits and investigations.

Lithuanian CASPs must strictly comply with all TFR regulations. This is strictly monitored by the Financial Crime Investigation Service (FCIS). The responsibilities of this authority include:

• monitoring compliance;
• providing recommendations and clarifications;
• conducting audits;
• imposing penalties.

To obtain detailed information regarding TFR compliance, consider consulting legal professionals.

Lithuanian AML Compliance Requirements

The FCIS and the Bank of Lithuania (BoL) strictly control Lithuanian CASPs’ compliance with anti-money laundering policies. Therefore, we will take a closer look at the requirements for providers in this area.

So, a CASP in Lithuania is required to:

1. Appoint a Money Laundering Reporting Officer (MLRO). This officer is responsible for overseeing AML/CFT policy compliance and interacting with regulators.

1. Conduct KYC (Know Your Customer) checks. Providers must verify clients’ identities and apply Enhanced Due Diligence (EDD) for specific categories of users.

These include politically exposed persons (PEPs), residents of high-risk countries, and individuals conducting large or suspicious transactions.

• Monitor transactions. Real-time transaction monitoring must be conducted by CASPs.

If suspicious activity is detected, a report must be sent to the FCIS within 24 hours of identification. This report must include information about the sender and beneficiary. The threshold transaction amount for reporting is €15,000.

1. Comply with the Transfer of Funds Regulation (TFR). CASP obligations in this area are described in detail above.

• Maintain records and reporting. The provider must retain client data, transaction records, and compliance documentation for at least five years. All data must be readily available for audits and investigations.

The company must also have a written AML/CFT policy and an organized employee training process for the respective procedures.

Having difficulty meeting AML Compliance Requirements? Enlist the support of experienced legal professionals and be confident that your operations are fully legal.

Stages of Obtaining a CASP License in Lithuania

Licensing of CASPs in Lithuania takes place in several stages:

Company Registration

The registration of a legal entity is a mandatory requirement for obtaining a Lithuania CASP license. To do this, you must contact the Centre of Registers and carry out the following actions:

• Choose a company name and check its availability (uniqueness);
• Prepare incorporation documents (Articles of Association and resolutions of the founders);
• Send the application electronically or through a notary;
• Obtain a company code and an official certificate of registration.

Once the legal entity is established, you can proceed to the next stage.

Opening a Bank Account

Opening a corporate account is a mandatory stage. Without it, you will not be able to fulfill another requirement – the deposit of the minimum capital.

When choosing a financial institution, make sure it is either a Lithuanian bank or an EU bank with a branch in Lithuania.

Preparation of Documentation

Prior to submitting the license application, the provider is required to prepare the following documents:

• AML/CFT policies;
• business plan;
• KYC models and risk assessment models;
• Company’s Articles of Association;
• declarations of directors and shareholders;
• proof of professional qualifications of key personnel;
• financial statements as evidence of the deposit of minimum capital.

All these documents must be submitted together with the application to the Bank of Lithuania.

Application Submission

“Applying for the license requires the provider to complete the standard form and submit it to the Bank of Lithuania (BoL), accompanied by the necessary documents.

Regulatory Review and Verification

The review of the application by the regulators includes:

• verification of the reputation and qualifications of the management team;
• evaluation of AML/CFT policies;
• request for additional documents or clarifications (optional).

Once all checks are completed, the provider receives the licensing decision.

License Approval

If there are no comments on the application and documents (or if they are corrected in a timely manner), the BoL issues the Lithuanian CASP license. The company will then be added to the Register of Crypto Asset Service Providers.

Post-Licensing Compliance

After receiving the license, the provider may begin operations in accordance with the business plan and regulatory framework. However, during operations it is also important to fulfill certain obligations:

• Regularly submit AML/CFT reports to the FCIS;
• Submit monthly reports to the BoL;
• Conduct internal audits and compliance checks;
• Be prepared for inspections from the FCIS or the Bank of Lithuania;
• Update the license in case of expansion of the range of services.

Lithuanian CASP License: Estimated Costs and Timeline

The process of CASP licensing in Lithuania generally takes up to eight weeks. This period includes the initial review (about 25 days) and a detailed assessment (about 40 days, with possible extension in case of a request for additional information).

As for the cost of obtaining a Lithuania CASP license, it is variable. It depends on the services offered and the complexity of the company’s activities. The total amount of expenses may include the cost of legal consultations, compliance services, and other overhead costs.

Why Choose Lawrange for CASP Licensing in Lithuania

AA Lawrange provides crypto service providers with comprehensive services in the field of licensing their activities in Lithuania and other jurisdictions.

With our team of professionals, you will receive:

• Extensive experience (10+ years) and deep industry knowledge, which will allow the procedure of obtaining a Lithuania CASP license to be as fast and effortless as possible;
• Full support from the moment of establishing a legal entity to ensuring post-licensing compliance;
• Comprehensive consultation on legal, tax, and accounting matters related to running a crypto business.

Contact the experts at Lawrange and launch your CASP in Lithuania without unnecessary delays!

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