1. Industry information：Lithuanian EMI approval cases and regulatory developments for Chinese and international companies
Paytend Technology (Chinese capital)
Chinese capitalFintech company Paytend successfully obtained approval from Lithuania EMI licenseand set up European headquarters。Its system is legally connected to the CENTROlink system of the Central Bank of Lithuania，Realize SEPA real-time clearing and cross-border card issuance business。
IBS (international commercial settlement)
IBS Lithuania, a subsidiary of a Hong Kong-listed company, obtains Lithuanian EMI license。Legally approved businesses include the issuance of debit cards andCross-border remittance，and supports WeChat payment (WeChat Pay) With Alipay (Alipay) in the European Economic AreaComplianceAcquiring。
InstaReM (Asia cross-border payments)
Singapore-based cross-borderpayment institution InstaReM obtained Lithuanian EMI license。Activate passport mechanism according to law (Passporting) back，Its business covers the European Union 27 country，Establishing a cross-border fund clearing channel between Asia and Europe。
DORA and MiCA Act Implementation
The EU’s Digital Operations Resilience Act (DORA) mandates the establishment of an ICT operational resilience system。《CryptoassetsMarket Regulation (MiCA) comes into force，Those who concurrently engage in virtual asset business must simultaneously apply for a CASP additional license in accordance with the law.。
2. [Statutory classification and capital standards] of Lithuania BoL payment license
| Statutory license type | Business authority and regulatory definition | Legal minimum paid-in capital |
|---|---|---|
| electronic money institution (EMI) |
Authorized to issue electronic money (e-money) and e-wallet，And can provide a wide range of payment and SEPA transfer services。 | 350,000 EUR。Must be deposited in pure cash with a BoL approved custodian bank。It is strictly prohibited to use assets or virtual currencies to offset capital contributions。 |
| payment institution (PI) |
Only payment intermediary services such as transfers can be provided，No authority to issue electronic money or retain customer balances。 | According to specific service type，Usually between 20,000 to 125,000 EURbetween。 |
| Cryptoasset service provider (MiCA CASP) |
as additional license。Authorized to provide virtual currency exchange、Legal currency deposits and withdrawals and digital asset custody services。 | At least 125,000 EUR。This capital must be in line with the EMI requirement 35 Ten thousand euros are calculated and stored separately。 |
legal affairsNote：The capital must be fully verified before submitting the application。Institutions must continue to maintain statutory capital adequacy ratios：Own funds shall not be less than 350,000 2% of the total liability in euros or e-currency (whichever is higher)。Below the standard must be in 10 Report within the day and submit a make-up plan。
3. Lithuania EMI’s [Statutory Requirements for Corporate Governance and Executive Officers]
Local entity registration：The applicant must register a limited liability company (UAB) locally in Lithuania，And provide the actual local registered office address。
Board configuration and localization：Equip at least two people with financial qualifications、Directors with payment or risk management experience。At least one of them must reside in the European Economic Area (EEA)，And submit proof of no criminal record and resume in accordance with the law。
Statutory Compliance Officer：A Compliance Officer (RO) and an Anti-Money Laundering Officer (MLRO) must be designated in accordance with the law.，To fulfill regulatory communication and suspicious transaction reporting obligations。At least one core person in charge must reside permanently in the EU。
Information Security and Data Officer：An Information Security Officer (ISO) must be appointed，Coordinate IT system security。If processing large amounts of customer data，Must file with the official Data Protection Officer (DPO) in accordance with the law，Enforcement of the General Data Protection Regulation (GDPR)。
Penetrating review of important shareholders：Investors with a shareholding ratio of ≥10% are legally defined as "significant shareholders"，Must undergo due diligence that reaches the ultimate beneficiary (UBO)，Provide proof of legal source of funds、Tax list and no criminal record。
4. Submitted to the Central Bank of Lithuania (BoL) [List of statutory review documents]
| File category | Submission details for statutory requirements (Important documents require notarized translations in Lithuanian) |
|---|---|
| Corporate foundation and audit documents | UAB company registration documents and proof of registered address。Management KYC documents。Employment commitment letter issued by a local registered auditor in Lithuania。 |
| Financial planning and fund tracing | Business plan covering financial calculations and capital flow。35Capital verification letter from the custodian bank for a capital of 10,000 euros。UBO Fund Source Legality Statement (provide bank statements/tax statements and other link certificates)。 |
| Compliance and IT Security Architecture | Anti-Money Laundering and Counter-Terrorism Financing Policy (AML/CFT)、Enhanced due diligence (EDD) procedures for high-risk customers。risk management structure。IT security instructions (including disaster recovery plan BCP/DRP) and data protection (GDPR) plan。 |
5. [Statutory Application and BoL Review Procedure] for Lithuanian EMI License
Stage one：Corporate establishment (about 2 week)
Complete Lithuanian local limited liability company (UAB) registration，Establish local legal office address。
Stage 2：Documentation and auditor appointment (about 4-6 week)
Writing business plans and AML/IT internal control and compliance policies，Prepare executive due diligence materials，Sign a local auditor cooperation agreement。
Stage three：Account opening and actual payment of funds (about 1-2 week)
Open a capital account at a BoL-approved custodian bank，Full injection 35 10,000 euros in cash and obtain a capital verification letter。
Stage four：File submission and supervisory interview (review period 3-6 months)
Submit full package of documents to BoL。BoL issues a written notice of supplementary documents (limited to submission within 30 days)，and compulsorily arrange online or on-site supervisory interviews，Assessing management’s ability to perform duties。
Stage five：Approval of licensing and passport activation (total cycle 6-9 months)
Obtain EMI license after passing the review。Submit the "Passport Application Form" to implement the EU notification procedure。Encountered multiple replacement parts，The overall cycle can reach 12 months。
6. Client funds segregation (Safeguarding) With [AML/IT Compliance Red Line]
Physical segregation requirements for funds：The customer's electronic money balance must 100% Independent from the company’s own funds。Funds must be deposited in a dedicated account of an EU-regulated custodian bank (or equivalent insurance must be purchased)，Organizations must implement daily automatic reconciliation and reconciliation (Daily Reconciliation)。
24Hourly STR Reporting Redline：A transaction monitoring system must be established。Suspicious transactions found，must be in 24 Submit a suspicious transaction report (STR) to the Lithuanian Financial Crime Investigation Service (FCIS) within hours and freeze funds in accordance with the law。
Data Territory and Audit Log：The system must have multi-layer security authentication (2FA/MFA)，PSD2 Strong Client Authentication (SCA) compliant。The main server and client cloud data must be located in the EEA。Transaction logs must be tamper-proof and kept at least 10 Year。
Emergency reporting mechanism：Major events such as system failure or data leakage，Must be in 24 Submit an Incident Notification to BoL within hours，and in 48 Submit accident analysis report within hours。
7. [Official Fees and Comprehensive Budget Standards] for Lithuanian EMI licenses
| Funding and Expense Categories | Legal requirements and budget standards (EUR) |
|---|---|
| Legal initial paid-in capital | lowest 350,000 EUR。Full payment must be made in pure cash into a BoL-approved escrow bank account。 |
| BoL official application fee | Payable to the central bank when submitting EMI application 1,463 EUR official fees。 |
| Local rigid maintenance costs | Local registered auditor and bank account opening fees are approximately 3,000 to 5,000 EUR。Independent network penetration testing must be performed regularly before the system goes online and during daily operations. (Pen Test)。 |
| Agency consultants and legal budget | Including overall project coordination、Compliance system document writing、Executive matching and interview guidance，The budget for professional services fees is usually 60,000 to 90,000 EUR interval。 |
8. Hong Kong Huitong's legal agency service for Lithuania EMI license case
Corporate establishment and localization of senior management
Process Lithuanian UAB company registration。Legally matched to meet BoL suitability (Fit & Proper) EEA Resident Executive Director Reviewing Standards、Anti-money laundering manager (MLRO) and information security officer (ISO)。
Core legal documents and system compliance
Write a business plan that includes a money flow model。Prepare an AML/KYC policy that complies with EU GDPR and PSD2 standards、IT disaster recovery mechanism (BCP/DRP) and data protection plan。
BoL Application and Interview Agent
Agent 35 Opening and capital verification of custodial account of 10,000 euros。Provide systematic supervisory interview coaching，Ensure that senior executives accurately answer anti-money laundering and fund isolation logic，Agent to license issuance and EU passport activation。
9. Lithuania EMI / CASP Regulatory License Core Legal Questions and Answers (FAQ)
After EMI approval，Submit Passport Notification Form to BoL，Describe target countries and service scope。BoL in 20 Notify the regulatory authorities of the target country within 3 working days，generally 30 Effective within days according to law，available in the EU 27 Provide cross-border services or establish branches in other countries。
Payment institutions (PI) can only provide transfer intermediary services；EMI is authorized to issue e-money and e-wallets，But only for fiat currency business。If it involves virtual currency exchange and custody，You must simultaneously apply for the CASP additional license under the MiCA framework。
Absolutely not。350,000 The minimum paid-up capital in Euros must be paid in full in pure cash to a BoL approved custodian bank account，It is strictly prohibited to use physical assets or virtual currencies to offset investment contributions。
Institutions must continue to maintain statutory capital adequacy ratios：Own funds shall not be less than 350,000 2% of the total liability in euros or e-currency (whichever is higher)。If it is lower than this standard，must be in 10 Report to regulators and submit capital replenishment plan within the day。
The customer's electronic money balance must 100% Independent from the company’s own funds。Must be deposited in a dedicated account of a custodian bank regulated by the European Union (or purchase insurance for the same amount)，And must perform daily automatic accounting and reconciliation (Daily Reconciliation)。
At least two directors with financial/risk control experience are required，One of them must reside in the European Economic Area (EEA)。A compliance officer (RO) and an anti-money laundering officer (MLRO) must be designated，Core regulatory communication positions must be based in the EU。
“Substantial shareholders” holding ≥10% of the shares must undergo statutory due diligence that reaches the ultimate beneficiary (UBO)。Complete bank statements must be submitted、Tax statements or equity transaction documents，Prove the absolute legality and traceability of capital injection。
System servers and customer cloud data must be located in the EEA。Must use a data center located in the EU and sign a Data Protection Agreement (DPA)。System must have 2FA/MFA multi-layer authentication，And the transaction log must be tamper-proof and kept for at least 10 Year。
The overall approval cycle averages 6 to 9 months。BoL will issue a supplementary notice (limited to submission within 30 days)，and compulsorily arrange online or on-site supervisory interviews，Conduct an in-depth assessment of management’s professional capabilities and anti-money laundering risk control systems。
Annual financial statements issued by local auditors must be submitted every year、Compliance review report and AML self-examination report。Quarterly returns must be performed through the online platform，Upload customer electronic money balance、Liquidity statements, etc.。
Upgrading to CASP requires additional submission of the MiCA Notification Form。According to new regulations，Issuing stablecoins anchored to legal assets must add liquidity reserves and disclose them in a white paper。CASP has independent capital threshold (minimum €125,000)，Must comply with EMI requirements 35 million euros calculated separately。
Lithuania EMI license has no fixed expiration date，Effective for a long time。However, if the company has serious violations (such as mixed use of funds)，or up to 10 days after approval 6 No substantive business has been carried out for months，BoL has the right to directly revoke or revoke the license in accordance with the law。
