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About Fintech Law in Skuodas, Republic of Lithuania

Fintech in the Republic of Lithuania operates under a national and European Union framework that is widely regarded as innovation friendly. Although Skuodas is a smaller municipality, companies based in Skuodas benefit from the same licensing, supervision and passporting opportunities as firms in Vilnius or Kaunas. Authorizations are granted at the national level by the Bank of Lithuania, and once licensed many activities can be passported across the European Economic Area.

Lithuania has become a prominent European hub for payment institutions, electronic money institutions and other technology enabled finance businesses. The Bank of Lithuania actively engages with market participants, offers regulatory consultations and operates a regulatory sandbox. The country supports open banking under PSD2, has robust but practical anti money laundering expectations, and has clear pathways for activities such as crowdfunding, crypto asset services under the EU MiCA framework, and specialized banking.

Setting up in Skuodas can be attractive if you want lower overheads while maintaining access to national infrastructure. Most fintech rules, approvals and supervisory interactions are handled centrally, while your registered office, employees and operations can be located in Skuodas.

Why You May Need a Lawyer

Licensing and authorization strategy is a common reason to engage counsel. A lawyer can help you determine whether your model requires an electronic money institution license, a payment institution license, an account information or payment initiation permission, a crowdfunding provider authorization, a MiFID investment firm authorization, a MiCA crypto asset service provider authorization or potentially a specialized bank license.

Compliance program design is critical. You will need help implementing anti money laundering controls, appointing and empowering a money laundering reporting officer, designing customer due diligence including remote onboarding, setting up transaction monitoring, screening and suspicious activity reporting, and aligning with sanctions requirements.

Data protection and cybersecurity obligations apply to most fintechs. A lawyer can help you navigate GDPR, determine whether you need a data protection officer, conduct data protection impact assessments and draft privacy notices, processing agreements and security policies aligned with European and Lithuanian requirements.

Contracting and consumer protection are central to product rollout. Counsel can prepare customer terms, pricing disclosures, dispute resolution clauses, outsourcing and cloud agreements aligned with supervisory expectations, and marketing reviews to avoid unfair commercial practices.

Corporate, employment and tax structuring benefit from legal input. You may need advice on selecting and forming a Lithuanian private limited company, governance and board composition, local presence expectations for key function holders, employment or contractor agreements, incentive plans and cross border tax considerations.

Regulatory engagement and disputes are areas where counsel is essential. A lawyer can guide pre application meetings with the Bank of Lithuania, respond to supervisory requests, manage audits and inspections, and represent you in enforcement or consumer complaints.

Local Laws Overview

Licensing and supervision. The Bank of Lithuania is the national competent authority for most financial market participants, including payment institutions, electronic money institutions, crowdfunding service providers, investment firms and banks. Lithuania also offers a specialized bank license that allows core banking services without certain investment services, with a lower initial capital threshold compared to a full bank. Licensed firms may passport services across the European Economic Area subject to notification procedures.

Payments and e money. PSD2 and its Lithuanian transposition govern payment services, strong customer authentication, incident reporting, open banking access and customer rights. Electronic money institutions and payment institutions must meet initial capital, safeguarding and governance requirements. The Bank of Lithuania supports direct access to payment systems and operates services that facilitate SEPA participation for eligible institutions.

Crypto assets. The EU Markets in Crypto Assets Regulation applies in stages, with stablecoin rules in effect and broader crypto asset service provider obligations taking effect. Firms providing crypto asset services will need authorization as crypto asset service providers from the designated Lithuanian competent authority and must meet prudential, governance, conduct, disclosure and safeguarding standards. Separately, Lithuanian anti money laundering law requires registration and compliance for virtual asset activities, with oversight of AML aspects by competent authorities. The EU travel rule for crypto transfers applies to obliged firms handling crypto transfers.

Anti money laundering and sanctions. Lithuania implements EU anti money laundering directives. Obliged entities must conduct risk assessments, perform customer due diligence including verification of beneficial owners, monitor transactions, retain records, screen against sanctions and report suspicious activity to the appropriate authority. Remote onboarding is permitted using a risk based approach with reliable electronic identification tools, video procedures and qualified electronic signatures consistent with national guidance.

Data protection. GDPR applies, complemented by the Lithuanian Law on Legal Protection of Personal Data. Firms may need to appoint a data protection officer, keep records of processing, implement technical and organizational measures, handle data subject rights and perform data protection impact assessments for high risk processing. The State Data Protection Inspectorate supervises compliance.

Crowdfunding. The EU Crowdfunding Regulation creates a single license for European crowdfunding service providers. The Bank of Lithuania acts as the national competent authority for authorization and supervision. Platforms must meet governance, investor protection, disclosure, conflicts management and complaint handling obligations.

Consumer and advertising rules. Consumer protection laws apply to financial promotions, contract terms, pricing disclosures, complaints handling and alternative dispute resolution. Marketing must be fair, clear and not misleading, including for crypto and investment related promotions. The State Consumer Rights Protection Authority oversees consumer matters for many sectors.

Outsourcing and ICT risk. Firms must align with supervisory expectations on outsourcing and information security, including risk assessments, exit strategies, access and audit rights and incident reporting. EU level frameworks on digital operational resilience for financial entities are being implemented and should be considered in technology planning.

Corporate and employment. Most fintechs use a Lithuanian private limited company as the operating entity. Governance, fit and proper criteria for managers and key function holders, and local presence expectations may apply depending on the license. The Lithuanian Labour Code governs employment, including rules for remote work, working time, leave and termination.

Frequently Asked Questions

Can I base my fintech in Skuodas and still get a Lithuanian license

Yes. Licensing and supervision occur at the national level, so a company with its registered office or operations in Skuodas can be authorized by the Bank of Lithuania. You must still meet all national requirements, including governance, staffing and local presence where applicable.

Do I need a physical office and staff in Lithuania

Most licensed entities must demonstrate effective management in Lithuania, including local decision making, responsible managers and a money laundering reporting officer. A purely virtual presence is unlikely to satisfy expectations. A physical office in Lithuania and locally based key function holders are commonly required.

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

Payment institutions provide payment services such as money remittance, payment initiation and account information. Electronic money institutions can issue electronic money in addition to providing payment services and must safeguard customer funds accordingly. The initial capital and ongoing obligations differ, and the appropriate license depends on your business model.

How long does authorization typically take

Timeframes vary by license and application quality. A well prepared payment institution application can often be assessed within several months, while electronic money institution and banking authorizations can take longer. The Bank of Lithuania encourages early engagement through pre application consultations to refine your plan and timeline.

What changed for crypto businesses with MiCA

MiCA introduces an EU authorization for crypto asset service providers and harmonized conduct, governance and safeguarding rules. If you provide services such as custody, exchange, order execution or advice on crypto assets, you will need authorization from the Lithuanian competent authority and must meet prudential and organizational requirements. Until fully transitioned, national AML registration and controls remain applicable.

Is remote customer onboarding allowed

Yes, subject to a risk based approach and robust controls. Lithuanian rules allow non face to face onboarding using methods such as qualified electronic signatures, video identification and reliable electronic identification schemes, together with sanctions screening and ongoing monitoring.

Can I passport my services across the EU

Yes. Most licenses granted in Lithuania, including payment institution, electronic money institution, crowdfunding provider and investment firm authorizations, can be passported to other European Economic Area countries via notification procedures. Passporting for MiCA crypto asset service providers will follow EU rules once authorized.

What are the key AML expectations for fintechs

Firms must perform business wide risk assessments, establish customer due diligence procedures, verify customers and beneficial owners, apply enhanced due diligence where needed, monitor transactions, keep records, screen against sanctions and report suspicious activity to the appropriate authority. A designated compliance officer and documented policies and training are essential.

Do I need a data protection officer

Not every fintech needs a data protection officer, but you must appoint one if your core activities involve large scale monitoring of individuals or large scale processing of special categories of data. Even without a mandatory appointment, you must comply with GDPR, maintain records of processing, implement security measures and handle data subject rights.

What is the specialized bank license in Lithuania

Lithuania offers a specialized bank license that allows acceptance of deposits and lending but excludes certain investment services. It has lower initial capital than a full scope bank and is designed to facilitate entry by new players. It still requires robust governance, risk management and compliance arrangements.

Additional Resources

Bank of Lithuania Financial Market Supervision Service. This is the primary supervisor for payment institutions, electronic money institutions, crowdfunding platforms, investment firms and banks, and the organizer of the regulatory sandbox and pre application meetings.

Financial Crime Investigation Service. This authority is involved in anti money laundering oversight and suspicious transaction reporting for obliged entities.

State Data Protection Inspectorate. This authority supervises GDPR and national data protection compliance and issues guidance on data processing and security.

State Enterprise Centre of Registers. This body handles company formation, beneficial ownership filings and certain registrations relevant to financial services firms.

State Consumer Rights Protection Authority. This authority oversees consumer protection, advertising and unfair commercial practices that can affect financial services marketing and customer relations.

Invest Lithuania and Startup Lithuania. These organizations provide information on doing business, talent, and practical steps for establishing operations, including in regional municipalities like Skuodas.

Skuodas District Municipality Administration. For local matters such as premises, business support programs and municipal requirements related to operating an office.

Next Steps

Clarify your business model. Write down the exact services you will provide, how you will make money, who your customers are, where they are located and how funds or assets will flow through your solution. Map activities to likely licenses or registrations.

Engage a lawyer early. Ask for an initial assessment that covers licensing options, timeline, capital and governance expectations, AML framework, data protection and consumer law. If you plan to operate from Skuodas, confirm local presence and staffing arrangements that meet national supervisory expectations.

Plan a pre application meeting. Prepare a concise deck and book a consultation with the Bank of Lithuania to validate the regulatory pathway, scope of permissions, safeguarding model, outsourcing plans and technology architecture.

Choose and form your entity. Most fintechs use a Lithuanian private limited company. Secure a registered address in Skuodas, appoint directors and key function holders and register beneficial ownership and other filings with the Centre of Registers.

Build your compliance stack. Draft AML policies and procedures, appoint an experienced money laundering reporting officer, select onboarding and screening tools, design transaction monitoring and sanctions controls, and document your risk assessment. Prepare GDPR documentation, including privacy notices, records of processing, processor agreements and security policies.

Prepare the application package. Assemble the business plan, program of operations, financial forecasts, internal control descriptions, governance documents, outsourcing and cloud materials, incident response plans and evidence of capital and safeguarding arrangements.

Set your timeline and budget. Include authorization fees, advisor costs, staffing, technology, insurance, audit and ongoing reporting. Establish board and committee calendars and internal audit or compliance monitoring plans.

Launch with controls. After authorization, implement customer support and complaint handling, regulatory reporting, incident management and change management processes. Keep an open dialogue with supervisors and update documentation as your product evolves.

This guide is for information only and is not legal advice. For advice tailored to your situation in Skuodas, Republic of Lithuania, consult a qualified lawyer with fintech regulatory experience.

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Disclaimer:
The information provided on this page is for general informational purposes only and does not constitute legal advice. While we strive to ensure the accuracy and relevance of the content, legal information may change over time, and interpretations of the law can vary. You should always consult with a qualified legal professional for advice specific to your situation. We disclaim all liability for actions taken or not taken based on the content of this page. If you believe any information is incorrect or outdated, please contact us, and we will review and update it where appropriate.