FAQ

Question
Newcomer: Payments
Which commercial bank a payment or e-money institution should choose for opening non-EUR payment accounts? Could you provide any recommendations?
Under anti-money laundering rules, is it possible to onboard clients online (i.e. non-face-to-face client identification)?
What kind of licence should we obtain if we want to open payment accounts (e-wallets)?
A payment or e-money institution must provide evidence that the minimum size of the equity capital does not fall below the amount specified in the Law on Payment Institutions and the Law on Electronic Money and Electronic Money Institutions. What constitutes sufficient evidence?
Can a payment or e-money institution refer to someone at the Bank of Lithuania in terms of ongoing assistance, advice, and documentation?
What is the extent of a payment or e-money institution supervision in Lithuania? Can it be carried out remotely?
What client fund safeguarding requirements apply to payment or e-money institutions?
What audit, review and reporting requirements Lithuanian regulators apply to payment or e-money institutions?
Are there any prescribed roles for the company manager of a payment or e-money institution? What is its level of authority?
Can a corporate entity (from the financial sector) be part of the management board?
What is the requirement for the size of own funds?
What items comprise the initial capital of a payment or e-money institution?
What is the minimum requirement for the number of people on site in terms of payment or e-money institutions? Are we required to base any of our directors in the Republic of Lithuania?
In terms of e-money institution authorisation, are we required to provide the Articles of Association at the licensing stage if we have not yet set up an entity in the Republic of Lithuania?
Does a payment or e-money institution have to be established and registered in the Republic of Lithuania?
Which licensing and supervisory documents need to be submitted in Lithuanian?
Newcomer: Retail Investment
Our brokerage firm wants to provide investment services related to binary options, CFDs (contract for difference) and Forex products. What will the Bank of Lithuania focus on when carrying out authorisation and supervision procedures?
If a brokerage firm (category C) does not intend to safe-keep client funds, the initial capital requirement for such a firm is no less than EUR 50,000. Is the firm expected to hold additional funds?
Are persons providing financial services to clients required to each get a brokerage licence or is the manager’s brokerage licence (i.e. a single financial broker’s license) enough?
Can a corporate entity (from the financial sector) be part of the management board?
What is the mandatory composition of the management of a financial brokerage firm?
Personal financial guide. Payments
	Customer due diligence
	Isn’t the payment service provider who is asking me to provide personal information about the origin of my funds requesting excess information?
	Fees
	What fee can payment service providers charge for the balance on a payment account?
	Where can I see the fees charged by payment service providers?
	Does the Bank of Lithuania regulate transaction fees of payment service providers?
	Is the payment institution where the transfer is effected obliged to inform me of the fee charged by the correspondent bank?
	How should a payment service provider publish currency exchange fees?
	Do I have to pay for an account I have not used for a long time because I have forgotten it?
	Payment accounts
	Is a payment service provider (PSP) obliged to inform me if restrictions have been applied to my payment account or a payment?
	How much time in advance must a payment service provider (PSP) inform me about the termination of the agreement on the initiative of the PSP?
	For how long can a payment service provider (PSP) apply restrictions on a payment account or a payment?
	How can a payment service provider (PSP) restrict my use of financial services, if I fail to provide the information required in a timely manner?
	Isn’t a payment service provider breaking rules by charging a monthly administration fee for a payment account if the account is subject to a restriction under the procedure established by court?
	Where can I find information on financial market participants operating in Lithuania?
	What do I need to do to open a payment account?
	Payment cards
	Can I disclose payment card data (holder’s name, payment card number and CVV code, PIN code) to others?
	Is a payment service provider obliged to block a payment instrument if it suspects fraud?
	What should I do if payment transactions are carried out without my knowledge and consent?
	Payments
	Can a bailiff transfer funds from my account without my consent?
	Can a payment service provider suspend the execution of a payment?
	If execution of a payment takes longer than projected, is the payment service provider obliged to pay compensation for the delay period?
	Can I choose between OUR or SHA payment method when making a transfer of funds?
	I suspect fraud, how should I behave?
	Is a payment service provider obliged to suspend a payment transaction if it suspects fraud?
	Can a payment service provider restrict or refuse performing fund transfers to or from belarus / russia?
	What does the OUR payment method mean?
	What does the SHA payment method mean?
	What is a correspondent bank?
	How long does it take to effect a SEPA funds transfer?
	How long does it take to effect an international payment?
	What is SWIFT / BIC code?
	What is IBAN?
	What is the Single Euro Payments Area (SEPA)?
	Can I cancel a transfer of funds?
	What should I do if I make a mistake in the first name or last name of the payee when making a payment transfer?
	Presentation of information
	Is the payment service provider obliged to provide the consumer with a report on the commission fee?
	How and when should a payment service provider inform customers about changes to the terms and conditions of payment services?
	Other
	Which of the two procedures to choose: a complaint or a dispute procedure?
	Are my accounts opened with payment service providers visible to other institutions?
	Can I get cash at an ATM other than the one of my payment service provider?
	Where can I get cash?
	What services can I receive when acting under a power of attorney?
	Within what period of time does the payment service provider have to refund the amount of an unauthorised payment transaction to my payment account?
	What risks I may be exposed to when investing in crypto-assets?
	Who is assigned the supervision of crypto-asset activities?
	Where should I apply with regard to legal relations of inheritance and regulation thereof?
	What does the Bank of Lithuania do to stop fraud?
	Can I cash a cheque in Lithuania?
	Is my account covered by deposit insurance?
	Do I have the right to object to changes to the terms and conditions of payment services?
Cash
	Exchange of euro and litas coins and banknotes
	Where can I exchange euro coins or banknotes into another denomination?
	How many euro coins can be exchanged at the cash offices of the Bank of Lithuania?
	Is it possible to exchange litas into euro at the cash offices of the Bank of Lithuania?
	Exchange of foreign currency
	Where can I exchange foreign currency?
	Where can I exchange invalid or worn foreign currency banknotes?
	Counterfeit and unfit-for-circulation money
	Where can I exchange worn or damaged euro banknotes?
	What should you do if you suspect that banknotes are counterfeit?
	Services provided at the cash offices of the Bank of Lithuania
	What services are provided at the cash offices of the Bank of Lithuania?
	What fees are applied for the services provided at the cash offices of the Bank of Lithuania?
	In what cases is it necessary to submit an authorisation in order to use any of the services provided at the cash offices of the Bank of Lithuania?
	Depositing and withdrawing cash at an ATM
	What should I do if the ATM does not issue money, but it is debited from my bank account?
	What should I do if cash was accepted when depositing cash in the ATM, but the amount was not credited to my bank account?
	What should I do if money is not recognised and accepted when depositing cash in the ATM?
	Acceptance of cash
	Is it mandatory to accept cash payments at all points of sale?
	Can merchants and service providers indicate to the customer that they accept only cash or only card payments? Is it legal for the merchant or service provider to specify the minimum amount for which they accept card payments at the time of purchase?
	Can merchants and service providers not accept euro coins for payment?
	Can merchants and service providers not accept €200 or €500 banknotes? What should a person with such banknotes do?
Rounding of cash payments
	For consumers
	From when does rounding of cash payments apply?
	Who must apply rounding?
	What is to be rounded?
	How is rounding applied?
	Why rounding is introduced? What is the purpose of rounding cash payments?
	Does rounding apply to the price of each good? Will the prices of all goods be rounded to the nearest 5 or 10 cents, e.g. the price of €0.99 to €1?
	Does rounding apply when goods are returned? Does rounding apply to refunds for services not provided, sub-standard services provided?
	If several goods purchased at the same time were paid for by a payment card, what is the amount to be refunded to a buyer who decides to return only one good and asks for a cash refund?
	Does rounding apply when goods are bought in?
	Does rounding apply to cash payment of invoices?
	Does rounding apply to cash payments for various services (e.g. utilities, telephone, internet, cable TV, insurance and leasing premiums, tuition, kindergarten fees, clubs, etc.)?
	Does rounding apply to cash payments for ride-hailing services?
	How is rounding done in the event of a non-cash payment?
	Does rounding apply to payments by payment card?
	Does rounding apply to payments made with gift vouchers (cheques, cards), money accumulated on loyalty cards, social cards?
	Does rounding apply to online sales?
	Does rounding apply to payments for meals ordered online?
	Is rounding applied to pensions and other social security benefits?
	Does rounding apply to salaries, daily allowances and posting expenses?
	Does rounding apply to taxes, tax-related amounts, levies, fines and other pecuniary obligations?
	Does rounding apply to currency exchange?
	Does rounding apply when depositing cash to a payment account or withdrawing cash from a payment account?
	Does rounding apply to cash remittances?
	Does rounding apply when depositing cash to a payment account or withdrawing cash from a payment account?
	How does rounding apply to premiums for reimbursable medicines?
	Does rounding apply to payments between legal persons?
	Can the buyer demand payment of the exact amount instead of a rounded amount?
	Can a buyer ask for a rounding of a non-cash payment?
	Where can I use an accumulated stock of 1 and 2 cent coins?
	With rounding, is the buyer entitled to pay for the purchase in 1 and 2 ct coins only?
	Can a retailer (service provider) refuse to accept 1 and 2 cent coins from a buyer when rounding?
	Can the change be given in 1 and 2 cent coins when rounding? In which cases?
	Can the buyer refuse to take change in 1 and 2 cent coins?
	Can change of €1 be given in 1 and 2 cent coins when rounding?
	Will 1 and 2 cent coins be abolished and no longer available for payment? Do I need to rush to exchange 1 and 2 cent coins? For how long will 1 and 2 cent coins remain in circulation? For how long will 1 and 2 cent coins be available for making payments and giving change?
	How is the amount to be paid rounded if the buyer wants to pay part of the amount in cash and part by payment card, or vice versa – part by payment card and part by cash?
	How is rounding applied when using accumulated loyalty points for payment?
	How is rounding applied when part of the amount is paid in gift vouchers (cheques, cards) or social cards and the remainder in cash?
	Will rounding increase prices?
	Will the plastic bags cost 5 cents because of rounding?
	How will consumer spending increase as a result of rounding?
	Where can I get advice on rounding?
	Which authorities monitor compliance with the Republic of Lithuania Law on the Rounding of Cash Payments?
	How will rounding changes be explained to people?
	Which services offered at Lietuvos bankas cash offices are subject to rounding?
	How is rounding applied when the buyer pays for goods/services in instalments (multiple payments)?
	In the case of online purchases, where the moment of payment is postponed, leaving the consumer the possibility to pay in cash at the time of collection of goods (without knowing, at the time of placing an order, which method of payment the consumer will ultimately choose at the time of collection), is the merchant obliged to provide the consumer with information on rounding before concluding a distance contract?
	Is rounding applied to repayment of credit or leasing?
	How is rounding applied when the buyer pays multiple invoices issued on different dates at the same time, and how many cash receipts must be issued? Should the amount of each invoice be rounded and three cash receipts be issued? Should the total amount of the three invoices be rounded and one cash receipt be issued?
	For merchants (service providers)
	From when does rounding of cash payments apply?
	Who must apply rounding?
	What is to be rounded?
	How is rounding applied?
	Why rounding is introduced? What is the purpose of rounding cash payments?
	Will the rounding be done by a cashier?
	Does rounding apply to the price of each good? Will the prices of all goods be rounded to the nearest 5 or 10 cents, e.g. the price of €0.99 to €1?
	Does rounding apply when goods are returned? Does rounding apply to refunds for services not provided, sub-standard services provided?
	If several goods purchased at the same time were paid for by a payment card, what is the amount to be refunded to a buyer who decides to return only one good and asks for a cash refund?
	Does rounding apply when goods are bought in?
	Does rounding apply to cash payment of invoices?
	Does rounding apply to cash payments for various services (e.g. utilities, telephone, internet, cable TV, insurance and leasing premiums, tuition, kindergarten fees, clubs, etc.)?
	Does rounding apply to cash payments for ride-hailing services?
	How is rounding done in the event of a non-cash payment?
	Does rounding apply to payments by payment card?
	Does rounding apply to payments made with gift vouchers (cheques, cards), money accumulated on loyalty cards, social cards?
	Does rounding apply to online sales?
	Does rounding apply to payments for meals ordered online?
	Does rounding apply to salaries, daily allowances and posting expenses?
	Does rounding apply to taxes, tax-related amounts, levies, fines and other pecuniary obligations?
	Does rounding apply to currency exchange?
	Does rounding apply to cash remittances?
	Does rounding apply when depositing cash to a payment account or withdrawing cash from a payment account?
	How does rounding apply to premiums for reimbursable medicines?
	Does rounding apply to payments between legal persons?
	Can the buyer demand payment of the exact amount instead of a rounded amount?
	Can a buyer ask for a rounding of a non-cash payment?
	Where can I use an accumulated stock of 1 and 2 cent coins?
	With rounding, is the buyer entitled to pay for the purchase in 1 and 2 ct coins only?
	Can a retailer (service provider) refuse to accept 1 and 2 cent coins from a buyer when rounding?
	Can the change be given in 1 and 2 cent coins when rounding? In which cases?
	Can the buyer refuse to take change in 1 and 2 cent coins?
	Can change of €1 be given in 1 and 2 cent coins when rounding?
	Will 1 and 2 cent coins be abolished and no longer available for payment? Do I need to rush to exchange 1 and 2 cent coins? For how long will 1 and 2 cent coins remain in circulation? For how long will 1 and 2 cent coins be available for making payments and giving change?
	How is the amount to be paid rounded if the buyer wants to pay part of the amount in cash and part by payment card, or vice versa – part by payment card and part by cash?
	How is rounding applied when using accumulated loyalty points for payment?
	How is rounding applied when part of the amount is paid in gift vouchers (cheques, cards) or social cards and the remainder in cash?
	How should a cashier deal with a buyer who has the exact amount in cash and refuses to pay the rounded amount?
	Does the cash register's display dedicated to the buyer has to show, among other information, the amount rounded and the total amount due after rounding?
	Which amounts should appear on the cash register’s display when the buyer does not yet know how much will be paid in cash and how much – by card?
	How shall retailers (service providers) prepare for the application of rounding of cash payments?
	Can retailer (service providers) opt out from rounding?
	Can retailers (service providers) also apply rounding to non-cash payments?
	Will rounding increase prices?
	Will the plastic bags cost 5 cents because of rounding?
	How will consumer spending increase as a result of rounding?
	How is rounding to be recorded in the accounts of an entity (seller, service provider) when the entity sells goods (services) and the payment is made in cash?
	How is rounding to be recorded in the accounts of an entity (buyer) when an employee of the entity pays in cash for goods (services) purchased to be used by the entity?
	Which amounts shall be shown in the accounting documents when rounding?
	Which amounts shall be indicated on the cash register's receipt when rounding?
	How shall rounding be recorded in the accounts when cash payments are made for services (e.g. utilities, telephone, internet, cable TV fees, insurance and leasing premiums, tuition, kindergarten and clubs fees, etc.) through a payment service provider (e.g. a Perlas terminal, the Lithuanian post office, a branch of a credit institution, a store checkout)?
	What to do if a retailer (service provider) has accounting forms not suitable for rounding? Can they be used for rounding?
	What effect does rounding have on the calculation of value added tax (VAT)?
	What is the effect of rounding on the calculation of corporate income tax?
	What is the effect of rounding on the calculation of personal income tax?
	What is the effect of rounding on excise duties?
	Where can I get advice on rounding?
	Which authorities monitor compliance with the Republic of Lithuania Law on the Rounding of Cash Payments?
	What is the liability for violating the Republic of Lithuania Law on the Rounding of Cash Payments?
	Examples of rounding when using a cash desk and a self-checkout; indication of information on the display of a cash register or self-checkout
	How will rounding changes be explained to people?
	How should the rounding be carried out when goods/services subject to rounding and amounts not subject to rounding are paid simultaneously? For example, a customer buys milk and bread, and wants to pay a fine; he pays in cash.
	Does the trader have to provide the customer with a choice of the sequence of payment instruments when paying with different payment instruments?
	Does rounding apply to the amount of a lottery or gambling cash prize payment?
	How is rounding applied when the buyer purchases goods online or over the phone and pays for the goods at the time of delivery (cash on delivery service), but it is not known whether the payment will be made in cash or by card?
	How is rounding applied to transport privileges? How much should a carrier be compensated for loss of revenue due to the application of the Law on Transport Privileges?
	How is rounding applied to insurance policy premiums when insurance policies are sold by an insurance agent (natural or legal person) under a mediation agreement with an insurance company? How much must the insurance agent pay to the insurance company? Who should bear the differences in revenue resulting from rounding?
	How will economic entities (including libraries) collect default interest when rounding is introduced?
	Which services offered at Lietuvos bankas cash offices are subject to rounding?
	How is rounding applied when the buyer pays for goods/services in instalments (multiple payments)?
	In the case of online purchases, where the moment of payment is postponed, leaving the consumer the possibility to pay in cash at the time of collection of goods (without knowing, at the time of placing an order, which method of payment the consumer will ultimately choose at the time of collection), is the merchant obliged to provide the consumer with information on rounding before concluding a distance contract?
	Is rounding applied to repayment of credit or leasing?
	How is rounding applied when the buyer pays multiple invoices issued on different dates at the same time, and how many cash receipts must be issued? Should the amount of each invoice be rounded and three cash receipts be issued? Should the total amount of the three invoices be rounded and one cash receipt be issued?
	How should the merchant/service provider apply rounding in cases of using a cash register that does not have the rounding functionality?
	Where should merchants put 1 and 2 cent coins received from buyers? May they use them to give change?
Disputes between consumers and financial market participants
What is the difference between a dispute and a complaint?
Is a consumer required to participate during the investigation of their dispute at the Bank of Lithuania?
What disputes between consumers and financial market participants are examined by the Bank of Lithuania?
What should I do if I am not satisfied with the decision of a bank, insurance company or another financial market participant, with whom I have concluded an agreement?
What is the term for applying to the Bank of Lithuania for the settlement of the dispute, if I have received a negative (unsatisfactory) reply from a financial market participant?
I would like to apply to the Bank of Lithuania regarding the settlement of a dispute with a financial market participant. What information and documents do I need to provide?
To whom and at what address should I submit all the required documents?
How does the Bank of Lithuania handle disputes?
Should you pay for the examination of a dispute at the Bank of Lithuania?
Where should I apply regarding the settlement of a dispute: to the court or to the Bank of Lithuania?
In what cases can the Bank of Lithuania refuse to examine a dispute?
Is the examination of disputes at the Bank of Lithuania public?
How long does it take to examine a dispute between a consumer and a financial market participant at the Bank of Lithuania?
What decisions are made by the Bank of Lithuania regarding the dispute between a consumer and a financial market participant?
Can a complaint to the court be submitted regarding the decision of the Bank of Lithuania?
What is an international consumer dispute?
I have purchased a financial product or service from a financial market participant operating outside Lithuania. Where should I apply in the case of a dispute over the provided financial service?
Prevention of money laundering and terrorist financing
	Customer identification
	Is it mandatory to obtain from the customer the documents, data or other information necessary to identify the customer? Can data obtained from databases or service providers be used?
	What are the requirements for determining the purpose and intended nature of the customer’s business relationship? Are there cases where the customer is not required to provide this information?
	Should the documents of a legal entity and copies of registration documents collected remotely be notarised or certified by an Apostille? Is an e-signature sufficient to validate these documents?
	Are financial institutions obliged to obtain a copy of the customer’s identification document when the customer is identified in accordance with Article 11(1)(3) of the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing?
	How should financial institutions, when identifying a customer as defined in Article 11(1)(3) of the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing, make sure that a proper identity document was used at the time of the issue of the qualified electronic signature?
	How should financial institutions verify a customer’s citizenship when using their driving licence for identification purposes? Is a driving licence issued in the United Kingdom, which is no longer part of the European Economic Area (EEA), a valid document for a customer’s identification?
	How can a financial market participant authenticate a customer in the physical presence of the customer if, at the beginning of the business relationship, the customer’s identity was established and verified upon receipt of their passport or identity card?
	Is it obligatory to check against public, reliable and independent sources for negative information that can impact the customer’s, its representative’s and beneficiary’s reputation (e.g. if a pre-trial investigation into the customer’s financial crimes is initiated, etc.) during customer identification and verification?
	Do paper versions of documents (e.g. copies of passports, shareholder registers and company’s articles of association, etc.) collected during customer identification have to be stored? Is it sufficient to store only electronic versions of the documents in the customer’s file, according to internal control procedures determined by the financial institution?
	Beneficial owner identification
	Who should be considered the beneficial owner of various legal persons (e.g. in cases of unions or associations of multi-family apartment house owners or in case of a legal person undergoing bankruptcy procedures)?
	How should a market participant identify a beneficiary, if a legal person’s ownership structure includes company the securities of which are traded on a regulated market in the Member States of the European Union or other foreign countries and which is subject to disclosure requirements compliant with European Union legislation?
	How should a market participant identify a beneficiary, if the legal person’s ownership structure includes companies registered outside of the Republic of Lithuania?
	How to identify a beneficiary?
	What criteria should be used for selecting reliable and independent sources for the verification of information on customers and beneficial owners? Can you list examples of such sources?
	International financial sanctions
	Is the financial institution obligated to screen a customer, the other party to an operation (transaction) and the banks or financial institutions involved in an operation (transaction) with respect to the applicable international sanctions where the operation (transaction) is carried out in Lithuania, the European Union and/or the SEPA zone?
	Are international sanctions applicable to payments for basic goods and services (e.g. foodstuffs, utilities, medical services, etc.)?
	What is the amount from which operations or transactions carried out by financial institutions should be screened for the application of international sanctions? Are grounds for customer identification set forth in Article 9(1) of the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing applicable in this case?
	Should a financial institution make a payment to an entity which is subject to European Union sanctions under a contract, agreement or obligations that were concluded or arose before the date of the enforcement of sanctions on the entity?
	Monitoring of business relationships
	When entering into a business relationship, is the customer always required to fill in a Know Your Customer (KYC) questionnaire? How detailed the questionnaire must be?
	Other
	What are the requirements for transferring (migrating) customers from a financial institution licensed outside Lithuania to a financial institution licensed in Lithuania?
	Can financial institutions wanting to install new technological solution to manage money laundering and terrorist financing (ML/TF) risks request the Bank of Lithuania (LB) to judge its acceptability and compliance with the requirements of the Law on the Prevention of Money Laundering and Terrorist Financing (hereinafter ‘the Law’) (in customer identification and verification, monitoring of financial operations and other stages)? If yes, can you briefly outline the procedure? If no, can you tell what other ways there are for the supervised entities to assess the applied technological solution’s compliance of with the Law and LB recommendations?
	While performing Ongoing Due Diligence on customer and beneficial owner, can financial market participant use data available in reliable external sources as the primary source? For example, data on the type of activity, management structure, manager (managers), beneficial owner, etc.
	What is the difference between the simplified customer due diligence case laid down in Article 9(4) of the Law on Money Laundering and Terrorist Financing (hereinafter – Law) and the case in Article 15(1)(7) of the Law?
	How frequently does information about the customer and the beneficial owner need to be updated?
Authorisation. Credit and payments market
	Banks and specialised banks
	Is a bank authorised to refuse to provide services to consumers or businesses?
	Is an institution that has obtained a banking licence in Lithuania obliged to provide banking services in Lithuania?
	Is a bank authorised to outsource part of its functions?
	Is a bank authorised to provide services in other EU Member States?
	Can the capital of the bank being established be formed from funds raised during an ICO?
	Is it necessary to form the capital of the bank being established prior to applying for a licence?
	Can I establish a payments bank?
	Is a specialised bank authorised to provide any financial services?
	Is the applicant obliged to submit a recovery plan?
	Can only citizens of the Republic of Lithuania who permanently reside in Lithuania become directors of a bank?
	Payment institutions and electronic money institutions
	What are the main requirements on the implementation of the internal audit function in electronic money and payment institutions?
	Can an electronic money or payment institution established in Lithuania and having a branch in another Member State carry out its activities in the branch only?
	In which cases may an electronic money or payment institution licence be withdrawn?
	Can the same persons be shareholders of more than one electronic money or payment institution in Lithuania?
	Can the initial capital of an electronic money or payment institution be formed later, i.e. after the institution has started operating and obtained the relevant licence?
	Is a licenced electronic money or payment institution authorised to open a branch or to operate as a non-established institution in a non-Member State? Where can I find information regarding the applicable requirements?
	Is a licenced electronic money or payment institution authorised to provide ancillary services related to payment services?
	What are the requirements for the management body of an electronic money or payment institution?
	What is the difference between an electronic money or payment institution licence for restricted activity and a standard electronic money or payment institution licence?
	Is an entity being established required to provide its articles of association or draft articles of association when submitting an application for an electronic money or payment institution licence?
	Should the management body of an electronic money or payment institution reside in Lithuania (meaning that they are present on-site)?
	A payment or electronic money institution must provide evidence to show that its minimum initial capital is not lower than the amount that has been established by law. Which documents are considered as valid evidence regarding the initial capital amount?
	Which documents a company has to submit to the Bank of Lithuania in order to be granted an electronic money or payment institution licence?
	Is an electronic money or payments institution obliged to have a supervisory board in place?
	Which main by-laws regulate the procedure for issuing (or replacing) an electronic money or payment institution licence?
	Can a legal entity being established apply for an electronic money or payment institution licence? What is the timeframe for registering a legal entity after the issuance of a licence?
	Other credit and payments market participants
	Does the Bank of Lithuania provide sample copies of the responsible lending and borrowing rules, business model description, business continuity plan or other documents?
	Does a consumer credit provider have to inform the Bank of Lithuania about new dependent intermediaries of the consumer credit provider?
	Is a supervisory board member of a consumer credit provider or a peer-to-peer lending platform operator considered as the director of that provider or operator?
	Does an individual, a consumer credit provider, or a peer-to-peer lending platform operator aiming to acquire shares of a crowdfunding platform operator have to submit an application to approve of the acquisition if the share of the crowdfunding platform operator which they plan to acquire amounts to less than 20% of the voting rights and/or the initial capital?
	Dependent and independent credit intermediaries acting under the Law on Real Estate Related Credit are obliged to have a document which confirms the existence of professional indemnity insurance for their undertaking with a minimum monetary value of €460,000 for each individual claim and a total value of €750,000 for all claims for a calendar year. Do the legal acts provide for any exceptions as regards to the indemnity amount?
	Can a consumer credit provider submit an application to include it in the Public List of Consumer Credit Providers after the Bank of Lithuania has removed it from the list?
	If a consumer credit provider or a peer-to-peer lending platform operator has not conducted any activities for more than six months, does it have to submit an application to be removed from the list?
	Do legal acts provide for a consumer credit provider, a peer-to-peer lending platform operator, or a crowdfunding platform operator to carry out their activities in another Member State after being included in the list?
	Is a legal person who is aiming to be included in the Public List of Consumer Credit Providers or Peer-to-peer Lending Platform Operators obliged to have their head office in the Republic of Lithuania?
	Do I need to fill out any specific application to be included in the Public List of Independent Consumer Credit Intermediaries or Intermediaries Acting under the Law on Real Estate Related Credit?
	Agents of electronic money and payment institutions and electronic money distributors
	What is the key difference between an EMI or PI agent and electronic money distributor?
	Does an electronic money distributor to be engaged by an EMI need to be included in the Public List of Electronic Money Institutions?
	When filing an application with the Bank of Lithuania with regard to an agent to be engaged by an EMI or a PI, does information on the agent’s management have to be provided?
	Which subordinate legislation of the Republic of Lithuania regulates the procedure for inclusion of EMI and PI agents into the Public List of Electronic Money and Payment Institutions, for notifications to foreign supervisory authorities of the intention to issue, distribute and redeem electronic money and to provide payment services in other Member States?
	What are the preparatory actions to be taken by an EMI or a PI before applying for inclusion of an agent in the Public List of Electronic Money and Payment Institutions?
	What are the preparatory actions to be taken by an EMI before engaging an electronic money distributor?
	Who is responsible for payment services provided through agents or for activities of electronic money distributors?
	What actions should be taken by an EMI or PI if it finds that an agent or an electronic money distributor is acting on behalf of the institution without complying with legislative requirements?
	In what way should consumers be informed that payment services are provided through agents or that electronic money distributors are engaged?
	What requirements for customer information are applicable to EMI or PI when activities are carried out through agents or electronic money distributors?
	What actions must be taken by an EMI or PI when it ceases to operate through an agent and wishes to exclude the agent from the Public List of Electronic Money and Payment Institutions, or when it ceases to operate through an electronic money distributor?
Authorisation. Insurance market
What documents do I need to submit when applying for the issuance of the insurance activity licence?
Are there any specific requirements for the name of an insurance undertaking?
Which legal form and registration requirements apply to undertakings aiming to carry out insurance activities? Can an insurance activity licence be granted to a legal entity which has not yet been established (entered into the Register of Legal Entities)?
Can an insurance undertaking transfer its licence to another undertaking which meets the requirements applicable to insurance undertakings?
What are the requirements for persons holding managerial positions and shareholders of insurance undertakings?
Which legal acts specify the requirements for an applicant aiming to be granted a licence to engage in insurance activities?
What is the state levy for the issuance of an insurance activity licence?
How long does it take to issue a licence to engage in insurance activity?
Are the undertakings holding a reinsurance activity licence authorised to engage in any economic activity not associated with reinsurance activity?
Are the undertakings holding a licence to engage in insurance activity authorised to engage in any other economic activity which is not associated with insurance activity?
Is a reinsurance undertaking authorised to engage in insurance activities of any insurance class?
Who has the right to engage in reinsurance activity in the Republic of Lithuania?
What is reinsurance activity?
Is an insurance undertaking authorised to engage in insurance activity of any insurance class?
Is an undertaking which holds an insurance activity licence also authorised to provide services in other states?
Who has the right to engage in insurance activities in the Republic of Lithuania?
What is insurance activity?
Authorisation. Market in financial instruments
What is the definition of a 'good repute'?
Should any state levy be paid for the issuance of a licence for a financial advisory company?
What documents should be submitted to the Bank of Lithuania to be granted a licence of a financial advisor company?
Which legal acts regulate the issuance of a licence for a financial advisory company?
What documents should be submitted to the Bank of Lithuania to be granted a licence (authorisation) of a management company?
Which legal acts regulate the issuance of a licence (authorisation) for a management company?
Should any state levy be paid for the issuance of a licence (authorisation) for a management company?
Should a person planning to temporary replace a director of a management company obtain the approval of the Bank of Lithuania?
Is it required to obtain the approval of the Bank of Lithuania not to oppose the proposed acquisition in order to acquire a qualifying holding of a management company?
Should a person planning to become a director of a management company obtain the approval of the Bank of Lithuania?
What requirements are applicable to directors of a management company?
What documents should be submitted to the Bank of Lithuania in order to be granted a licence of a financial brokerage firm?
Which legal acts regulate the issuance of a licence for a financial brokerage firm?
Should a financial brokerage firm pay any state levy for the issuance of a licence?
Should a person planning to temporary replace a director of a financial brokerage firm obtain the approval of the Bank of Lithuania?
Is it required to obtain the approval of the Bank of Lithuania not to oppose the proposed acquisition in order to acquire and manage a qualifying holding in a financial brokerage firm?
Should a person planning to become a director of a financial brokerage firm obtain the approval of the Bank of Lithuania?
What requirements are applicable to management body of financial brokerage firms?
Authorisation. MiCAR
What are the expectations of Lietuvos bankas regarding entities seeking a licence as a crypto-asset service provider?
What documents are required to be submitted to Lietuvos bankas for the issuance of a licence as a crypto-asset service provider under the MiCA Regulation?
How will crypto-asset services be provided during the transitional period?
How will the suitability of managers and their collective suitability be assessed?
What will be the amount of a fee charged to crypto-asset service providers for the issuance of a licence and how will it be paid?
How should crypto-asset service providers safeguard their clients’ crypto-assets and funds?
How should applicants submit documents to Lietuvos bankas for a licence as a crypto-asset service provider?
Can the custody and administration of crypto-assets on behalf of clients be outsourced?
Can crypto-asset services be provided through an intermediary?
When must the applicant submit audited financial statements?
Can a company registered in Lithuania, which has been issued an electronic money institution licence in accordance with the Republic of Lithuania Law on Electronic Money and Electronic Money Institutions or has been issued a payment institution licence in accordance with the Republic of Lithuania Law on Payment Institutions, apply to the Bank of Lithuania with a request to additionally issue a crypto-asset service provider licence under MiCAR to this company?
Can existing financial market participants provide crypto-asset services before the entry into force of Regulation (EU) 2023/1114 of the European Parliament and of the Council (Markets in Crypto-Assets Regulation; MiCAR)?
Do operators of virtual currency exchanges and/or operators of depository virtual currency wallets established in the Republic of Lithuania have to apply to the Bank of Lithuania before the entry into force of Regulation (EU) 2023/1114 of the European Parliament and of the Council (Markets in Crypto-Assets Regulation; MiCAR) regarding the granting of a licence to carry out these activities?
Will the virtual currency exchange operators and depository virtual currency wallet operators currently operating in the Republic of Lithuania and intending to operate in accordance with Regulation (EU) 2023/1114 of the European Parliament and the Council (Markets in Crypto-Assets Regulation; MiCAR) be subject to lower requirements?
Can a crypto-asset service provider, having received the appropriate licence in accordance with Regulation (EU) 2023/1114 of the European Parliament and the Council (Markets in Crypto-Assets Regulation; MiCAR), provide services in more than one Member State (cross-border provision of services)?
What would be the recommendations of the Bank of Lithuania for crypto-asset service providers regarding the number of employees or organisational structure?
Authorisation. Questions regarding the formal requirements for documents submitted to the Bank of Lithuania
How application for authorization should be submitted?
Complete this questionnaire to see whether you are prepared for the licensing process.
What duties arise from the change of managers and shareholders of a financial market participant?
In what languages should the documents be drafted to be accepted by the Bank of Lithuania?
Do all the documents drafted and/or issued in a foreign country have to be legalised or certified with an Apostille?
What information is required to justify the origin of funds?
Should board members who are not employed by a financial market participant submit a questionnaire for the director or key function holders of the company?
We are ready to submit an application for a licence or an application to be included in the public list, but the procedure of legalisation or confirming by APOSTILLE stamp has not been finalised for some of the documents drawn up (issued) by foreign authorities. Is it possible to submit the application to the Bank of Lithuania and to provide the missing documents later, during the process of examining the application?
The Bank of Lithuania has returned the documents to the applicant due to the deficiencies in their form. Is it possible to re-submit the application?
Do any deficiencies in the content of documents always result in a refusal of the Bank of Lithuania to issue a licence or to authorise inclusion in the public list?
Can copies of documents submitted to the Bank of Lithuania be certified by a company director?
CENTROlink
	Features of direct participation
	What is the difference between direct participation in a payment system and participation through the addressable BIC model?
	Is our EMI or PI a direct participant in the CENTROlink payment system?
	Our institution is satisfied with the status of an addressable BIC holder. Are we required to become a direct participant?
	If we make few payments, do we need direct participation?
	Is it possible to participate in the CENTROlink payment system indirectly?
	Preparation of EMIs and PIs licensed in Lithuania for direct participation
	When will the provisions of SFD and PSD2 be transposed into Lithuanian law?
	When will all the documents, forms to be completed, etc. be approved?
	What legislation governs the direct participation of EMIs and PIs in payment systems?
	What requirements must EMIs and PIs licensed in Lithuania seeking direct participation in the CENTROlink payment system fulfil to demonstrate compliance with Article 35a of the PSD2?
	On what basis were the migration windows defined?
	When will the information about the migration windows be made available?
	What steps should we take during the designated migration window?
	Can you move the designated migration window forward or postpone it?
	Guidelines for completing the compliance report form
	Preparation for direct participation by EMIs and PIs licensed both within and outside Lithuania
	What changes will take effect from 9 April 2025?
	We have recently submitted a completed CENTROlink due diligence/know your customer (KYC) questionnaire. Will we need to submit a new one in preparation for direct participation?
	The SFD and PSD2 have not yet been transposed in our national law. How does this align with the established agenda?
	Will the transition to the direct participation model require new technical integration?
	How will the technical process of connecting to the CENTROlink payment system evolve?
	When will the liquidity management tool be improved?
	What happens if we are not ready for direct participation by 9 April 2025?
	We have contacted the licensing authority but have not received a response regarding the transposition of the directives. What should our next step be?
	The CENTROlink payment system has so far provided customer funds safeguarding account services. How will customer funds be safeguarded after 9 April 2025?
	Currently, liquidity adjustment between SCT and SCT Inst accounts is available only until 6 p.m. (EET). At what point can an extension of this timeframe be expected?
	TARGET
	Will direct participants in the CENTROlink payment system be able to participate in the TARGET system?
	We intend to continue using CENTROlink payment system services but we do not require access to the TARGET system. Is this type of participation possible?
	Development of the system during the migration period
	We would like to become participants in the CENTROlink payment system. Do we need to wait for the completion of the migration process?
	We would like to join the additional SEPA scheme. Do we need to wait for the completion of the migration process?
	Key dates
	Until when will the CENTROlink payment system provide customer funds safeguarding account services?
	Until when can an unlimited amount of customer funds be held in the CENTROlink payment system?
	When must requests for direct participation, including additional documentation, be submitted to the CENTROlink payment system?
	How long will the assessment of the request for direct participation take?
	When is the direct participant agreement expected to be signed?
	When are the technical changes related to the migration process expected to be completed?
	When is the migration process expected to be completed?
	Participation of EMIs and PIs licensed in the United Kingdom in the CENTROlink payment system
	We are an EMI or PI licensed in the United Kingdom. What are the options for us to continue using CENTROlink payment system services?
	Other
	What regulations will govern relationship between participants in the system and the CENTROlink payment system?
Payment and electronic money institutions
Is it necessary to inform Lietuvos bankas about the contracts that were upgraded from unimportant to important?
Outsourcing of operational functions
Is it necessary to inform Lietuvos bankas about the contracts that were upgraded from unimportant to important?
Can the bank delegate its internal audit function to another person?
Are data provision/receipt contracts (for example, with State Enterprise Centre of Registers, credit bureau Creditinfo Lietuva, UAB) attributed to outsourcing contracts?
Can the functions for the performance of which an authorisation is needed be outsourced to a service provider established in a non-EEA state?
Is the business model of an electronic money institution or a payment institution, whereby intermediaries act on behalf of FMPs in other EU states, considered as the outsourcing of operational functions under Resolution No 03-166 of the Board of the Bank of Lithuania of 10 November 2020 on the Approval of the Rules on the Outsourcing of Operational Functions of Financial Market Participants (hereinafter – the Resolution)?
Is the participation of the FMP in the CENTROlink payment system via the Bank of Lithuania considered as the outsourcing of operational functions under Resolution No 03-166 of the Board of the Bank of Lithuania of 10 November 2020 on the Approval of the Rules on the Outsourcing of Operational Functions of Financial Market Participants (hereinafter – the Resolution)?
Is the opening of a payment account in a credit institution, where an electronic money institution or a payment institution holds customer funds separately from the FMP or makes customer payments, considered as the outsourcing of operational functions under Resolution No 03-166 of the Board of the Bank of Lithuania of 10 November 2020 on the Approval of the Rules on the Outsourcing of Operational Functions of Financial Market Participants (hereinafter – the Resolution)?
Is the outsourcing of the accounting function considered the outsourcing of an important function?
Is it possible to delegate the control functions to other parties?
Is the outsourcing of the compliance function considered as outsourcing of operational functions under Resolution No 03-166 of the Board of the Bank of Lithuania of 10 November 2020 on the Approval of the Rules on the Outsourcing of Operational Functions of Financial Market Participants (hereinafter – the Resolution) and, if yes, is it considered an important function?
Does the Bank of Lithuania need to be informed in advance of the outsourcing of the internal audit functions of electronic money institutions and payment institutions?
In case the contract for the outsourcing of operational functions had already been assessed by the Bank of Lithuania (i.e. prior to December 2020), does the FMP have to present the updated contracts for the outsourcing of important operational functions to the Bank of Lithuania once again in accordance with the requirements set in Resolution No 03-166 of the Board of the Bank of Lithuania of 10 November 2020 on the Approval of the Rules on the Outsourcing of Operational Functions of Financial Market Participants?
The Bank of Lithuania needs to be informed in advance about the outsourcing of important operational functions. What functions are attributable to important operational functions?
Statistics
Where can I find information on resident savings and investment?
What is the institutional sector?
What are financial accounts and how do they differ from financial accounts?
Where can I find information on price indices, price developments, etc.?
Where can I find information on interest rates in line with market prices?
Where can I find information on the life assurance and non-life insurance market?
Where can I find information on cash flows received by natural persons from abroad?
Does the Bank of Lithuania prepare information on the export and import of services by country?
Where can I find information on the investment results of companies managing pension funds?
The Bank of Lithuania website publishes aggregate statistical data. Can I find individual data by each respondent, e.g. a bank?
Other
When concluding a loan agreement secured by a surety and/or a guarantee, does a financial institution have a duty to apply to the surety provider and/or guarantor the same LPMLTF provisions as those applied to a customer (borrower)? Which moment should be considered as the moment of initiation of a business relationship with the surety provider and/or guarantor in the sense of Article 9(1)(1) of the LPMLTF?
A Company provides only payment initiation services (hereinafter – PIS). When does it have the obligation to identify the customer (PIS user) and the beneficiary, and when can the exemption provided for by the AML/CFT law on simplified customer identification be applied?
Equivalence regime. What is the equivalence regime in financial services and is it applicable to the United Kingdom (UK)?
Is a customer whose relative is a politically exposed person should be treated as one as well?
Is a financial institution required to check for the payee and/or the payee’s bank in the lists of applicable international sanctions at the time when a non-cash transfer operation is being performed within the SEPA area?
Is a financial institution required to conduct verification of the payee and/or the payee’s bank regarding higher-risk factors (e.g. if the beneficiary is a PEP, the beneficiary is considered to be of poor reputation, a pre-trial investigation regarding financial crime has been initiated against the beneficiary) at the time when the financial institution’s customer (payer): - performs a non-cash transfer operation to the payee within the SEPA area; - performs a non-cash transfer operation to the payee outside the SEPA area; - performs a low-value non-cash transfer operation to the payee within/outside the SEPA area; - performs a high-value non-cash transfer operation to the payee within/outside the SEPA area;
If all transactions (monetary operations) by a financial institution’s customers are executed through an account held with a credit institution, is it required to register customer operations amounting to or exceeding €15,000 in a separate register? Is it enough to store account statements with all customer transactions and mandatory data of monetary operations on a regular basis?
What are the criteria for choosing the right tools for identifying and verifying the source of the customer’s funds and assets? Could you give examples of suitable information sources or documents?
Is it not necessary to require customers to provide their representative’s identity document and documents confirming registration of the legal entity, as well as data on the beneficiary and the management structure, when applying simplified customer (legal entity) due diligence?
Which reliable sources are recommended for verifying information provided by the customer regarding politically exposed persons (hereinafter ‘PEP’)?
Must paper and/or electronic versions of the results of customer screening performed by persons responsible (e.g. search on the Internet or in relevant databases, etc.), customer risk assessment and other information related with meeting the requirements of the Law be stored?
When identifying the beneficiary, is it necessary to receive an identity document copy from the beneficiary (natural person)? Is it sufficient to request from the customer only obligatory data as regards the beneficiary?
When identifying the customer (legal person) in its (its representative’s) physical presence, is it necessary to acquire the paper versions of the documents identifying the legal person or proving its representative’s authorisation, or is it sufficient to receive them by email or in other electronic form from the customer’s representative?
Upon expiry of the identity document obtained in the beginning of the business relationship and in physical presence of the customer, can financial market participant update the identification data of the customer and the customer’s identity document data relying on data available in reliable sources, e.g. the Population Register?
When performing Ongoing Due Diligence regarding the purpose and intended nature of the customer’s business relationships (e.g. cash operations, international transfers, etc.), can financial market participant as a primary source use customer’s transaction history?
When applying simplified customer due diligence, to which extent should customer’s data be collected?
In what cases is simplified customer due diligence allowed?
What the position of senior manager referred to in Article 2(23) of the Law on the Prevention of Money Laundering and Terrorist Financing (hereinafter – Law) should entail?