Best Fintech Lawyers in Marijampolė

About Fintech Law in Marijampolė, Republic of Lithuania

Marijampolė is part of Lithuania’s nationally coordinated fintech ecosystem. While your team and operations can be based in Marijampolė, the key authorizations, supervision, and consumer dispute processes are administered at the national level by the Bank of Lithuania and other central authorities. Lithuania is known across the European Union for a pragmatic regulatory approach, an active supervisory dialogue, and efficient authorization timelines for payment institutions, electronic money institutions, crowdfunding platforms, and other financial innovators.

Fintech in Lithuania operates within the European Union legal framework. This means that local rules in Lithuania align with EU directives and regulations such as PSD2 for payments, GDPR for data protection, the EU Crowdfunding Regulation for platforms, and MiCA for crypto assets as it phases in. Companies can often passport approved services across the European Economic Area once licensed. For founders and teams in Marijampolė, this creates a practical mix of local presence and EU reach.

Why You May Need a Lawyer

You may need a fintech lawyer when selecting the right regulatory perimeter. For example, deciding whether your product is a payment service, electronic money, investment service, crowdfunding, lending, or an unregulated technical service can materially change licensing scope, capital needs, timelines, and ongoing obligations.

You may also need legal help to structure licensing applications and regulatory strategy. This includes preparing internal policies, safeguarding arrangements, outsourcing and cloud contracts, open banking access models, and senior management accountability frameworks expected by the Bank of Lithuania.

Anti-money laundering and counter-terrorist financing compliance is an area where legal advice is critical. You will need to design a risk assessment, customer onboarding and due diligence, sanctions screening, transaction monitoring, reporting to the Financial Crime Investigation Service, and governance of your AML officer.

Data protection and cybersecurity require legal input to align your product with GDPR, local data protection guidance, and sectoral security requirements. This touches consent flows, privacy notices, data processing agreements, cross-border transfers, vendor management, incident response, and penetration testing obligations.

Marketing and consumer protection controls are important for Lithuanian retail customers. You will need compliant disclosures, terms and conditions in Lithuanian when targeting local consumers, fair pricing presentation, clear complaint handling, and adherence to local advertising standards for financial services.

Crypto and digital asset businesses need targeted advice on transitional rules under EU MiCA, Lithuanian AML and registration requirements for virtual asset service providers, custody and safeguarding models, and governance expectations.

Cross-border operations and corporate structuring benefit from legal planning. This includes passporting, the use of branches or agents, outsourcing to group entities, intellectual property, executive residency expectations, and tax implications.

Disputes and investigations also call for counsel. A lawyer can represent you before the Bank of Lithuania, the consumer dispute resolution body at the Bank of Lithuania, tax and data protection authorities, and Lithuanian courts or administrative tribunals.

Local Laws Overview

Licensing and supervision: The Bank of Lithuania licenses and supervises payment institutions, electronic money institutions, investment firms, crowdfunding service providers, consumer credit providers, and credit intermediaries. Many fintech activities require prior authorization or registration. Authorization enables EU passporting subject to notification rules.

Payments and e-money: PSD2 applies. Payment institutions and electronic money institutions must meet governance, safeguarding, capital, and reporting requirements. Customer funds must be safeguarded through segregation or equivalent protection. Electronic money is not a bank deposit and is not covered by deposit insurance.

Open banking and access to accounts: Account information and payment initiation services require authorization or registration. Access to bank APIs follows PSD2 standards and national guidance. Strong customer authentication and secure communication are mandatory.

Crowdfunding: The EU Crowdfunding Regulation sets a single regime for business crowdfunding across the EU. Providers need authorization and must meet investor protection, due diligence, and disclosure duties. There are rules on marketing, conflicts of interest, and investor onboarding.

Crypto and digital assets: Lithuania requires virtual asset service providers to register and comply with enhanced AML obligations. Governance, fit and proper management, and internal controls are expected. The EU MiCA framework is phasing in, with stablecoin rules already effective and crypto asset service provider authorization requirements applying according to EU timelines. Firms operating in Marijampolė should prepare for transition to MiCA authorizations and technical standards.

AML and sanctions: The Law on the Prevention of Money Laundering and Terrorist Financing imposes customer due diligence, ongoing monitoring, suspicious transaction reporting, and sanctions screening. The Financial Crime Investigation Service supervises AML compliance for relevant entities. EU sanctions apply and must be integrated into screening and controls.

Data, privacy, and cybersecurity: GDPR applies alongside Lithuanian data protection rules and guidance from the State Data Protection Inspectorate. Fintech firms should implement data minimization, lawful bases, transparent privacy notices, vendor management, and records of processing. Cybersecurity obligations can apply under sectoral rules and the Law on Cybersecurity. Incident response and breach notification timelines must be followed.

Consumer protection and marketing: When targeting Lithuanian consumers, information must be clear, fair, and not misleading. Terms should be available in Lithuanian. Specific rules apply to credit advertising, fees, APR disclosure, distance contracts, and out-of-court dispute resolution. The State Consumer Rights Protection Authority and the Bank of Lithuania have roles in oversight.

E-signatures and remote onboarding: Qualified electronic signatures compliant with eIDAS are legally equivalent to handwritten signatures. Remote identity verification is allowed under AML rules with appropriate risk controls and technologies. Lithuanian solutions such as mobile and smart ID methods are widely used.

Tax and accounting: Lithuanian corporate income tax and VAT rules apply, with specific exemptions or rules for certain financial services. Fintechs must maintain proper accounting, statutory filings, and consider transfer pricing if operating in multiple jurisdictions. Crypto taxation rules differ for businesses and individuals and require tailored analysis.

Company formation and local presence: Companies are registered with the Centre of Registers. Some financial licenses expect effective management and compliance functions in Lithuania. Day-to-day supervisory interactions and inspections are typically handled in Lithuanian or English. While you can base operations in Marijampolė, many regulatory interactions occur electronically or in Vilnius.

Dispute resolution: Consumers can submit complaints to the financial service provider and, if unresolved, to the Bank of Lithuania for out-of-court settlement. Regulatory decisions can be appealed in administrative courts. Arbitration and mediation are available where appropriate.

Frequently Asked Questions

Do I need a license to provide a payment app in Marijampolė if my company is Lithuanian?

If your app performs regulated payment services such as issuing payment instruments, money remittance, or payment initiation, you likely need authorization as a payment institution or electronic money institution from the Bank of Lithuania. A pure technical service that does not touch funds or initiate payments may be unregulated, but this requires a careful legal assessment.

What is the difference between an electronic money institution and a payment institution?

Both can provide payment services. An electronic money institution can also issue electronic money that represents a monetary claim on the issuer. Electronic money issuance triggers extra safeguarding and redemption duties. A payment institution cannot issue electronic money but can offer payment services like transfers or acquiring.

Can a Marijampolė based startup offer crypto exchange services?

Yes, but it must meet Lithuanian registration and AML requirements for virtual asset service providers. This includes governance, fit and proper management, and compliance controls. The EU MiCA regime will replace national regimes, so firms should plan for conversion to a crypto asset service provider authorization.

How long does it take to get licensed by the Bank of Lithuania?

Timelines depend on the license type and the completeness of your application. Lithuania is known for efficient processing and pre-application dialogue. A realistic plan includes time for preparation, Q and A with the supervisor, and possible iterations on policies and capital or safeguarding arrangements.

Do my customer terms have to be in Lithuanian?

If you target Lithuanian consumers, you should provide pre-contractual information and key terms in Lithuanian. Bilingual documentation is common. For business to business relationships, English is often used, but clarity on governing language is important.

Can I passport my Lithuanian license to other EU countries?

Most EU financial licenses, including payment and e-money authorizations, can be passported to other EEA states by notifying the Bank of Lithuania, which then informs host authorities. You must follow host country conduct rules and any local consumer protection nuances.

Is open banking available in Lithuania for fintechs?

Yes. Under PSD2, banks must provide secure APIs to licensed account information and payment initiation service providers. You will need proper authorization or registration, strong customer authentication, and adherence to security standards.

What are the key AML expectations for a fintech in Marijampolė?

Have a documented business risk assessment, risk based customer onboarding, sanctions and PEP screening, transaction monitoring, suspicious activity reporting to the Financial Crime Investigation Service, appointment of an AML officer, staff training, and audit or independent testing of your AML framework.

How are customer funds protected at an electronic money institution?

Customer funds must be safeguarded, usually by segregation into dedicated accounts with a credit institution or investment in secure low risk assets, or by an equivalent insurance or guarantee mechanism. These funds are kept separate from the institution’s own funds.

Where do customers file complaints about my fintech service?

Customers should first complain to your company using your internal procedure. If unresolved, consumers can bring the complaint to the Bank of Lithuania’s out-of-court dispute resolution body. You must inform customers of this right and keep clear records and response timelines.

Additional Resources

Bank of Lithuania Financial Market Supervision Service. Primary licensing and supervision authority for payment, e-money, investment, crowdfunding, and related services. Operates a regulatory sandbox and manages consumer dispute resolution for financial services.

Financial Crime Investigation Service. Supervisory authority for AML and sanctions compliance, receives suspicious transaction reports, and issues guidance on financial crime prevention.

State Data Protection Inspectorate. National data protection authority providing GDPR guidance, handling notifications and investigations related to personal data processing and breaches.

State Consumer Rights Protection Authority. Oversees compliance with consumer protection and advertising rules for consumer facing products and services.

State Enterprise Centre of Registers. Company incorporation, changes to corporate data, and public registers relevant to regulatory filings and disclosures.

State Tax Inspectorate. Corporate and VAT registration and guidance on tax compliance for businesses operating in Lithuania.

Invest Lithuania. National agency that provides practical information for establishing and scaling fintech operations in Lithuania, including talent and regulatory landscape.

Fintech associations and hubs in Lithuania. Industry groups that share best practices and regulatory updates, and provide networking opportunities for teams based in Marijampolė.

Marijampolė Municipality Business Support. Local information on business permits, office space, and community initiatives for companies operating in the city.

Lithuanian Bar Association. Directory for finding licensed attorneys with fintech and financial regulatory expertise.

Next Steps

Step 1 - Clarify your business model. Map every feature of your product to potential regulated activities. Determine whether you touch funds, issue stored value, access bank accounts, arrange credit, provide investment services, or facilitate crypto transactions.

Step 2 - Select the regulatory pathway. Decide whether you need authorization, registration, or can operate as an unregulated technical service. Consider future roadmap items that might change your perimeter.

Step 3 - Engage a fintech lawyer. Request a scoping memo covering licensing options, AML and data obligations, governance, timeline, and cost ranges tailored to operating from Marijampolė.

Step 4 - Prepare core documentation. Build policies for AML, risk management, safeguarding, outsourcing and cloud, operational resilience, data protection, incident response, complaints, and governance. Draft customer terms in Lithuanian where required.

Step 5 - Set up structure and resources. Incorporate or adapt your Lithuanian entity, appoint fit and proper management, designate an AML officer and data protection lead, secure local presence if needed, and implement technology controls for security and monitoring.

Step 6 - Submit applications and liaise with supervisors. Use pre-application meetings to validate your approach, respond promptly to questions, and adjust materials as needed. Plan for passporting if you will serve other EEA markets.

Step 7 - Launch with controls and testing. Run go-live checklists, penetration tests, data protection impact assessments, and staff training. Establish MI and board reporting for ongoing compliance.

Step 8 - Monitor regulatory change. Track updates on MiCA, AML rules, cybersecurity requirements, and consumer protection guidance. Schedule periodic independent audits and policy refresh cycles.

This guide is for general information. For advice on your specific situation in Marijampolė and across Lithuania, consult a qualified fintech lawyer who can help you plan and execute a compliant market entry and scale-up.