Licensing / Authorization
LITHUANIAN VIRTUAL CURRENCY EXCHANGE & WALLET CUSTODY OPERATOR
CRYPTO REGULATED COMPANY
Here are the Lithuanian requirements for a setup of a regulated VASP:
Lithuania requires an experienced Director in the finance industry, but not a local;
Lithuania requires a compliance person that from 01.11.2022 has to be a local resident;
Lithuania does not require a local physical office unless needed to register a VAT number;
Lithuania holds an authorized company in the public status, this is a link based on the Company Registry and with an official appointment of the MLRO to the regulator;
Lithuanian authorization is issued by the Registry and legislated by the Bank of Lithuania (regulated and investigated by Financial Crime Investigations Service unit)
Lithuania can apostille the respective proof of authorization in one company registry extract;
No minimum capital requirement in Lithuania until 01.11.2022, after that a minimum formal share capital of EUR 125'000 will be applied;
A Lithuanian State fee is approx. EUR 180 and only up to 4 weeks of timing to consider the license application, which on average takes us 1-2 weeks;
Lithuania does not need a criminal record (unless the owners and directors are publicly listed with negative information).
Lithuania's average salary in the accounting, compliance and sales field is by approx 10-20% lower than that of Baltic neighbor Estonia and 30-40% lower than in Central Europe;
In summary, Crypto companies conduct their business from Lithuania for a number of the following reasons:
1. Remote management of the company and easy appointment process.
The owner of the company can start and manage the company from abroad.
2. Transparent tax system.
According to the Law on Corporate Income Tax "Virtual currency" is a means of payment for goods and services. While virtual currency is considered the same as FIAT currency from a VAT perspective.
3. Easy to comply with requirements.
A company needs at least one owner, one managing director, and AML Compliance Officer who can also be the same person as the owner and MD. All clients must undergo a background check and identification procedure, also customer data must be kept on the company servers in case of an inquiry by FCIS. Furthermore, the company must have AML rules and procedures and notify any transactions to FCIS as per the local AML law.
4. For those who are able to visit, Lithuania it is worthwhile to consider e-Residency, which is similar to that of the e-residency card in Estonia and allows you to manage company decisions/sign documents digitally.
To authorize Lithuanian company for crypto exchange and wallet operations activity
On the procedural side to acquire the "crypto license in Lithuania" we cooperate with a local Law Firm that has to communicate further with the regulator, prepare application forms, do the UBO structure review, and prepare and or amend the AML rules in accordance with the Lithuanian legislation. This process with our advisory will cost from €4900.
REGARDING THE BANKS
While jurisdictions such as Estonia, Poland, Portugal, etc. offer to issue a license for VASP activities, the same companies cannot easily open a bank account in their respective country due to internal bank policies, thus you will not be able to have the same IBAN country on most occasions, but Lithuania with its financial infrastructure can provide solutions with the same country IBAN due to more than dozen of fintech operating with crypto-related projects. Furthermore, in Lithuania during the registration process our partnered Corporate Service providers, will open a bank account, first, a temporary account for share (equity) capital and then convert it into a regular current account for administrative use. And the account can be used for various non-crypto purposes including a collection of equity investments, profits from other company-owned bank accounts, etc.
We can advise and help on applications with acquiring providers, SEPA, EUR SWIFT, GBP’s, USD (ACH) domestic, white-label, and wire transactions each separately to their respective payment solution providers and classic banks. It takes about 2 weeks, minimum, to open one such bank account, and from our experience at least 1-2 weeks of time to collect appropriate KYC before handing in an application form.
One operational/business account costs from €800.
What if I have staking, digital asset trade, NFT, and or ICO platform?
Lithuanian crypto license does not regulate the abovementioned under one company and or platform. We would require a second company that has Authorization of Financial Brokerage firm or Authorization of Electronic Money Institutions. Inquire us for more in-depth details or upon your request we can supply a respective legal opinion regarding each of the activities with the help of our business partners.
LIST OF OTHER LICENSES
That we can mediate swiftly along with internal and external license requirements
The crowdfunding regulations also allow it to operate within the Crypto industry, which makes it a very attractive structure to many already established crypto exchanges. Furthermore, European Union has the Central regulation for Crowdfunds, thus passporting from Lithuania to other EU member states is a great advantage. The Legal fee to advise through the application process is starting from €15 500. More about the capital requirements, etc. Read here. The timeline to establish is approx. 3-4 months. While 6-7 months for crypto-related projects, taking from the experience.
CONSUMER CREDIT INTERMEDIARY
Legal fee from €3350. More about the license requirements Read here. The timeline to establish is approx. 7-14 business days.
CURRENCY EXCHANGE OPERATOR
Legal fee from €9500. More about the license requirements Read here. The timeline to establish is approx. 4 weeks.
LITHUANIAN EMI LICENSE
Legal fee from €25 400. More about the license requirements Read here. The timeline to establish is approx. 6-9 months.
Legal fee from €60 000. More about the license requirements Read here. The timeline to establish is approx. 14 months.
KYC requirements must be passed by each of our customers without exception. For this purpose, we will ask you to share with ALT Accounting MB - a copy of the passport and proof of address from both the Ultimate Beneficial owner(s) and Director(s), and to pass ID liveliness verification.