VASP Registration
New requirements from November 2022

Cryptocurrency Exchange and Trade – Atrium Legal Lab
Lithuania VASP Registration
New Requirements from 1st November 2022

Lithuanian authorities have officially announced approaching changes in regulation of virtual currency exchange and depository operator activities. Upcoming requirements are hereby described in great detail and showing its practical implementation, so that you have a clear understanding of Lithuanian VASP market situation and help you find the most suitable solution.

These new requirements will step into the force on 1 November 2022 for new applicants and on 1 December 2022 for already registered companies:

1. According to the current legislation of Lithuania, it is possible to obtain 2 separate registrations as “operator of deposit virtual currency funds” and “virtual currency exchange operator”.
In Lithuania it will remain activity registration (rather than a license) and the supervisory authority will be the Commercial Registry for compliance with formal requirements (availability of authorized capital; local exclusive AML officer, etc.).

2. Lithuanian authorities will create a separate register for Virtual Asset Service Providers by Jan-Feb, 2023 and it will be possible to upload a separate printout and further apostille to present it to the Banks, counteragents and other third parties.

3. Currently, contributed share capital is in the amount of 2 500 EUR.
As per new requirements:
– This share capital will be increased to 125 000 EUR;
– It will be allowed by the law to contribute only 31 250 EUR (25% of the initial share capital requirements) at the registration step;
– The amount of 31 250 EUR could be further withdrawn and used within the framework of the company’s activities;
– By the moment of submitting the annual report within 12 months after company incorporation, capital on the account should be not less than 50% (62 500 EUR).

Thus, the company’s equity capital cannot fall below 50% (62 500 EUR) at the moment of each annual report submission and further withdrawn and/or used within the framework of activities.

4. Currently, there is the requirement for an officially employed Money Laundering Reporting Officer (MLRO) and a non-local AML officer.
As per new requirements:
– Instead of MLRO and non-local AML officer, VASP will be obliged to have an exclusive (work only for one company) local AML officer.
– As per our initial assessment, Lithuanian authorities will not verify the competence of a local AML officer (such as CV, diploma, etc. will not be requested by the regulatory authorities). This is the point which allows you to have plenty of different options of hiring AML officers with the experience and occupation you will be satisfied with.

5. Currently, Director and UBO of a company do not have to be locals.
Requirements will remain the same.

6. To date, Director and UBO of a company should have a good reputation however, government authorities do not request the provision of no-criminal record.
In the line with amended legislation, an increase in the reputation requirements of the director and UBO will be applied.
From the practical perspective regulatory authorities as well as before most likely will not require to provide the criminal record of a company’s major actors, as well as verify their competence through interviews, CV gathering, etc. There will be more clarity on the implementation of this requirement when relevant changes to the secondary legislation will be made in October 2022, when FNTT issues the relevant guidance.

7. To date there is no need to have a physical substance in terms of office rent.
Based on the new legislation act, this requirement will not be a subject to change either.
Our advice is to rent a small premise to show the regulator real physical presence on the territory of Lithuania where the local AML officer could potentially work (upon your choice). It will also arise probability of success in the process of a corporate account opening.

Pricing for Crypto Registration in Lithuania

TBA is ready to provide you excellent solutions for crypto exchange and wallet licenses, inclusive the possibility to process crypto license application remotely, with no physical presence required in Lithuania.
Our Business Development Team will take care of all legal procedures on your behalf.
For more information or detailed offer specific to your own project, please contact us.

Licensing Services
Our Company Services
Services we DO and Services we DO NOT DO

Our company is EXCLUSIVELY engaged in assisting worldwide clients, either individuals or corporate entities, to get duly and properly registered and licensed with local Regulators and Financial Authorities to get respective official licenses to legally carry out their cryptocurrency business activities.

Atrium Legal Lab does not carry out any sort of cryptocurrency business trade or financial service!

Should you have an enquiry
You would like to discuss with us
You can either call or email us.

One of our Customer Representatives will be most pleased to help and assist you

Send us your message Now!
Legal disclaimer

The information and materials contained in this website do not constitute an offer, invitation, solicitation, advice or recommendation to buy the products and services offered and rendered by Atrium Legal Lab and shall be applied with prior consultation.

Atrium Legal Lab does not offer legal or tax advice without consultation with certified professionals with related appropriate skill and expertise.

The information contained in this website is for general guidance on matters of interest only and should not be considered as guidance for financial or tax decisions, or a substitute for specific professional consultation.

Atrium Legal Lab is not a bank, nor does it provide banking services. Atrium Legal Lab offers international company formation, corporate administration services, and bank/broker introductory services and account opening assistance.

This website is only used for promotional marketing purposes of Atrium Legal Lab and is not intended to portray that this is the site of a bank. All prospective clients should consult a properly qualified tax professional in their own country to determine their own tax implications prior to embarking on any strategy described in this website. Since laws in each country are different, constantly change and can be subject to different interpretations by courts of law, any information herein regarding tax minimization needs to be verified by such competent counsel. While we have made every effort to ensure that the information contained in this website is accurate and correct due to constant changes in laws, rules and regulations Atrium Legal Lab Ltd accepts no liability for any loss or damage arising directly or indirectly from action taken or not taken relying on the information contained in this website. In particular no warranty is given as to the completeness, accuracy, reliability of such information and as to whether it is at all times up to date.

Atrium Legal Lab accepts no liability for any loss or damage direct or indirectly arising from the application of any information contained in this website, including any loss, damage or expenses arising from, but not limited to, any defect, error, mistake, inaccuracy, reliability of this website, its contents or related services, or due to any unavailability of this Site or any part thereof of any contents or related services.

Notice About Restricted Customers / Citizens

Due to our internal policies to prevent fraudulent activities or violations of our internal AML policies we are regretting that we do not provide consultations, email support, on-boarding activities and customer care to all OECD black listed countries and their citizens / entities.