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An electronic certified extract (ESI) issued by the Register of Legal Entities is an extract of relevant company data. ESI is valid until the data, information, or documents are changed in the Register of Legal Entities (e.g. after registration of a new manual, statutes, director, or change of other registered data and information, registration of new or changed documents). It is often requested by the local authorities to instead of Registry extract PDF, you may be asked to present an ESI code - a string of numbers that can be checked, if valid via link here.

A legal entity, branch, or representative office wishing to obtain a new ESI (access key) must submit an application in the prescribed form for the issuance of an electronic certified extract from the register. The application can be submitted in person and or by post to any customer service unit of the Register Center or electronically through the customer service system of the Register Center.

To order the service electronically, the head of the legal entity or his / her authorized person must log in to the customer self-service system, and submit orders online.

If a legal entity, branch, or representative office uses an ESI (access key), we recommend ordering it when applying for registration of changes in data and/or documents. In this case, the ESI will be formed by registering the changed data and/or documents.

Important: company contact detail in the Register of Legal Entities must be up to date. Every newly ordered ESI will be sent to the company email and mobile phone which are submitted to the Register of Legal Entities. New ESI will be sent to the mobile phone, only if the number is in Lithuanian (+370….).

The ESI includes the data about any authorizations, and it is one of the official documents to prove that the company is eligible to provide virtual currency exchange operator activities in accordance with Lithuanian legislation. It also is considered with similar power to other country equivalents to Certificate of Good Standing, Certificate of Incumbency, Certificate of Incorporation, List of Directors; and in a case where there is sole shareholder it also keeps the data of shareholder list - all in one extract.

ALT Corporate can assist to order ESI, firstly, we should be registered on behalf of the company as one of the representatives and it requires the Power of Attorney process. Please refer to the pricing

One ESI code usually is delivered within a few hours, during the working office hours, however, can take up to 2 business days according to the Register Center.

Most financial institutions in Lithuania do not have a VAT number. So what should you do? Follow their example or take your own approach?

Why do companies apply for VAT, especially in the EU? Historically, it has been a tool to return the value-added tax within the same country if you have purchased any goods or services for the need to conduct your own business activity. Ever since the EU took its economic agenda to ease up and generate a great deal of trade between the members in the union and thus avoid double taxation, that also included an agreement clause for the VAT. When a VAT registered EU member sells or buys any goods or services from another VAT Registered EU member, then the active VAT is 0% (with certain provisions and exclusions). Hence, considering that the financial institution, with a target market in the EU, will also have significant costs in the same region, especially for marketing, maintenance, various supporting activities, etc. thus to save on such costs of 21% is a great deal and thus an argument why to apply for VAT.

However, most financial institutions do not. And it is for the following reason. VAT is intended for the local market, and why the VMI (Lithuanian tax authority) put their attention to the requirements to fulfill:

  1. Local list of customers and business partners that the company regularly transacts with;

  2. Local employees that are paid the social tax;

  3. Local office in the address that is not used by other companies (as a virtual office);

  4. The company exceeds EUR 45k revenue per 12 months basis;

And then, should you have the VAT, that would mean that the European private and corporate customer(s) who don't have a VAT registered in the EU, for any legal services provided (e.g. account opening) by the financial institution would be charged their fees + 21% (standard VAT rate).

Therefore, the decision is always on the company and it all depends on the individual cases, but mostly it is better to remain without the VAT registration. For more information, be sure to connect with ALT Accounting team.

"Now when the company is ready to operate, we go to the bank, or financial institution, or liquidity provider (e.g. Kraken), or AML & KYC provider, or with regular business partners and are asked for a proof of license, license number or the certificate". Whereas, whatever is the case, and they are quite unique every time - 1 out of 3 companies will definitely need additional proof of license, but the rest can probably live and sustain without it.

[UPDATED 01.02.2023] So how do you prove that the company has a license?

There are 5 ways, in our practice how it can be done. The three official ways are the public registry recordings. The first and simplest way that was introduced from the 1st of February, 2023, is via a public list -

Second, via public recording about registered documentation -

Should you change the company code and "search", the company should have an original recording "Pranešimas juridinių asmenų registro tvarkytojui apie vykdomą virtualiųjų valiutų keityklos operatoriaus ar depozitinių virtualiųjų valiutų piniginių operatoriaus veiklą" that translates in "Notification to the Registrar of Legal Entities about the activities of a virtual currency exchange operator or a deposit virtual currency operator".

Thirdly, the registry card (via ESI code), that also refers directly, in paragraph 10, to both authorizations separately (10.1. Depozitinių virtualiųjų valiutų piniginių operatorius and 10.2. Virtualiųjų valiutų keityklos operatorius).

On some occasions, we are asked "if the Term from Lithuanian translation is a date of expiry?" It is not. That is the day when we registered the application for crypto exchange activity and authorization. All licenses, until today, are without an expiry date, termless.

The license application is submitted to the Bank of Lithuania who also performs the UBO review. However, as crypto exchanges are not considered fully pledged financial institutions they are not listed on the Bank of Lithuania website. After the registration is granted, the Financial Crime Investigation Service (FCIS) is responsible for monitoring the company activities and making requests in order to check that all AML/KYC policies are followed per requirements of the law. The FCIS does not publicly publish the list of its monitored entities or issue a PDF certification that is the case in Estonia. Nevertheless, the regulation is similar and through AML legislation, referring to

The registry is the entity that stores and publicly represent the information about the company, therefore, it is the entity to show if you are authorized in the virtual currency exchange and wallet custody operator activity.

The third way to prove the license. In accordance with the AML law, every crypto exchange in Lithuania must appoint an MLRO (money laundering reporting officer). This person can be a non-resident, but he has to have applicable experience, and he has to be appointed, by the means of email communication. This is notification based and should you present one such email sent directly to the Regulator, most financial institutions will recognize and accept it as additional proof. ALT accounting can further organize the instructions and guidelines with a text, content, email details, and attorney at law official legal letter to confirm this process.

The fourth. Should all the above be considered and you are still stuck, then you must consider having a Legal Opinion from an Attorney-at-law. Legal opinions can be different:

  • a plain reference for confirmation of activities - works well with, e.g. Kraken;

  • a reference for eligibility for crypto exchange and wallet custody activities with some guidelines regarding KYC and AML requirements. Works with Swiss and non-EU financial institutions;

  • fully described information about the company scope of activities, guidelines to the AML tasks, and current regulatory provisions, often used - requested with specific agenda for establishing relations with government institutions locally and abroad, any legal concerns, self-educational, provisional for future financial product use.

We are here to help thus you can easily navigate through the local infrastructure, should you have any feedback and need any assistance, do not hesitate to inquire

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