Lithuania Compliance Guide

Regulatory framework

• Law on the Prevention of Money Laundering and Terrorist Financing (revised 2023).
• Bank of Lithuania guidelines for EMIs and payment institutions on remote onboarding.
• BoL Expectations for VASP internal control systems (Circular No. 03-213, 2022).
• EU AMLD6 baseline with local expectations for enhanced due diligence of high-risk third countries.

Customer onboarding

Lithuanian supervisors emphasise strong remote onboarding controls, independent verification, and retention of localisation artefacts.

Identity verification

AutoKYC orchestrates ID document capture with liveness and compares against Lithuanian Civil Registry data and EU watchlists. Support for eIDAS-compliant identification via Smart-ID and Mobile ID.

KYB and UBO tracing

Integrations with the Register of Legal Entities and UBO register, automatically extracting controlling persons and validating representative authority.

Risk segmentation

Pre-built rule pack covering BoL high-risk indicators (non-face-to-face onboarding, crypto-to-fiat ramps, cross-border PSP activity). AutoKYC can require multi-analyst approval for risk level “C” or higher.

Ongoing monitoring & reporting

Both EMIs and VASPs must maintain near-real-time oversight of transactions and report to the Financial Crime Investigation Service (FCIS).

• Continuous screening against FCIS and EU consolidated sanctions lists with daily refreshes.
• Transaction anomaly detection configured for Lithuanian thresholds (cash loading, card-to-card, crypto withdrawals).
• Built-in STR/SAR templates formatted for FCIS reporting with Lithuanian-language narrative options.
• Automatic triggers for updating customer risk profiles when travel rule matches indicate new counterparties.

Governance expectations

The Bank of Lithuania scrutinises AML governance, outsourcing oversight, and compliance staff expertise.

• Documented AML/CTF policy and procedures mapped to AutoKYC configuration with version control.
• Compliance dashboards tracking EDD volumes, escalation backlog, and analyst productivity.
• Outsourcing register capturing AutoKYC’s role, SLA metrics, and exit strategies.
• Training records for internal staff and outsourced analysts aligned to BoL requirements.