Bank of Lithuania
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During a target inspection of Wallter UAB, an electronic money institution, the Bank of Lithuania disclosed violations of the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing, which resulted in a warning, a fine and certain obligations imposed on the institution. The company has started the correction of violations and shortcomings on its own initiative already during the inspection.  

The Bank of Lithuania revealed that, during the period under inspection, the customer risk assessment procedures applied by the institution had not ensured an adequate identification of money laundering and terrorist financing risks of its customers as well as an appropriate classification of the customers into risk groups. 

The institution had not always identified its customers and their representatives properly, while KYC procedures were insufficient to understand the objective and nature of the activities of its legal entity customers. Wallter UAB had not ensured the application of enhanced customer due diligence procedures for higher risk customers and the regular updates of customer verification information.

Moreover, violations were ascertained in organising the monitoring of business relationships and transactions of customers: the institution did not have in place appropriate measures to collect sufficient knowledge about customer-specific behaviours, which would enable a proper identification of unusual transactions and operations. 

Wallter UAB had not performed a proper assessment of the documents provided by customers proving payment operations, transactions, their purpose or the origin of funds, superficially analysed complex and unusually large transactions and insufficiently examined the grounds and objectives for performing such transactions. In addition, in the period under inspection, the institution had not ensured independence of the internal control function, which is responsible for the organisation of the prevention of money laundering and terrorist financing, from business interests.

For these violations, the Bank of Lithuania imposed a fine of €280 thousand on Wallter UAB. In addition to that, the Bank of Lithuania warned the institution about the violations ascertained in the organisation of the training process for its staff. The Bank of Lithuania obligated Wallter UAB to eliminate all violations and shortcomings identified during the inspection by 31 March 2022. The institution has already taken action on its own initiative to ensure the elimination of these deficiencies and their prevention in the future.


Information on enforcement measures applied by the Bank of Lithuania, complaints concerning the imposed sanctions and the results of their investigations can be found here.