amendments to current  regulation applicable to crypto companies

Amendments to current Lithuanian regulation, one part of which entered into force in November 2022 and the other - in early 2023, brought more regulatory clarity for crypto businesses, also introduced some additional requirements.

The main changes include:

- the requirement for carrying out part of the activities in Lithuania, however, the law does not specify what specific part of the activities must be carried out in Lithuania;

- higher share capital requirements, i.e. the share capital of privated limited liability company has to be at least 125,000 EUR, however, it is possible to make only a part of the initial contribution to the share capital at the beginning;

- stricter requirements for the reputation of the members of management and supervisory bodies as well as the beneficiaries of the crypto company;

- prohibition for AML officers to represent more than one crypto company at the same time (exception applies when the crypto company belong to the same group of companies);

- obligations to have at least one senior manager permanently residing in Lithuania to ensure proper implementation of the AML/CTF requirements and efficient communication with the Lithuanian Financial Crime Investigation Unit;

- prohibition to open anonymous accounts or accounts with fictitious names;

- all authorised crypto companies in Lithuania will be included in the public list maintained by the Register of Legal Entities which shall be published on its website.

Having the necessary experience we are ready to help clients meet these requirements and provide advice on how to implement them better and easier.