Lithuania

Key Requirements

• Establish Lithuania-based legal entity with place of business in Lithuania subject to Bank of Lithuania supervision.
• Maintain minimum capital per MiCA Annex IV: €50,000 (Class 1), €125,000 (Class 2), or €150,000 (Class 3) based on service scope.
• Implement governance structure with board-level oversight, compliance officer, and risk management functions.
• Adopt customer asset safeguarding procedures with segregated custody arrangements and written safeguarding agreements per MiCA Article 72.
• Develop comprehensive AML/CFT program aligned with 5th EU Money Laundering Directive with transaction monitoring.
• Implement DORA operational resilience framework including business continuity planning and incident response procedures.
• Establish fair pricing and non-discriminatory order execution procedures for platform operations.
• Maintain professional indemnity insurance covering minimum 25% of quarterly fixed overheads per MiCA requirements.

Application Process

1. 1.Establish Lithuania-based company with articles of association, management documentation, and beneficial ownership information.
2. 2.Prepare comprehensive business plan including organizational structure, service offerings, AML/CFT procedures, and strategy.
3. 3.Document capital adequacy with €50,000-€150,000 minimum per service class through bank accounts and investment documentation.
4. 4.Prepare detailed operational procedures covering customer onboarding, AML/CFT compliance, and asset safeguarding.
5. 5.Submit CASP authorization application to Bank of Lithuania with business plan, governance documents, and compliance framework.
6. 6.Provide evidence of professional indemnity insurance and safeguarding arrangement documentation.
7. 7.Engage with Bank of Lithuania during 65-working-day assessment period responding to information requests.
8. 8.Receive Bank of Lithuania authorization decision and register in national register with EU passporting notification.

Ongoing Obligations

• Maintain minimum capital requirement per service class with quarterly capital calculations reported to Bank of Lithuania.
• Submit annual audited financial statements and governance reports to Bank of Lithuania by statutory deadlines.
• Report material incidents or regulatory violations to Bank of Lithuania within 24 hours of discovery.
• Conduct annual internal governance review with board approval and submit documentation to Bank of Lithuania.
• Update AML/CFT compliance procedures annually addressing identified risks and regulatory guidance changes.
• Maintain professional indemnity insurance continuously covering minimum 25% of quarterly fixed overheads.
• Notify Bank of Lithuania of material changes including shareholders, management, or service offerings within 30 days.