--- title: "Lithuania (LT) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/lithuania/ source_html: /jurisdictions/lithuania/index.html description: "Financial integrity intelligence for Lithuania (LT): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 4ab8d59c303d4c236fbcf888ac83272e2393718255118cac6762a991b4b15427 generator: "fe-fleet/md-twin@1.0" --- # Lithuania (LT) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Lithuania LT Domains covered 7 of 8 Sources 125 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Largely Compliant Tier: B Risk direction: Stable Enablement vs enforcement: Mixed Lithuania applies the EU AML/CFT acquis (AMLD transposition, forthcoming AMLR/6AMLD) via the Law on Prevention of Money Laundering and Terrorist Financing, supervised by the Financial Crime Investigation Service (FNTT/FCIS) and the Bank of Lithuania for financial/EMI/crypto obliged entities. More A fast-growing EMI and VASP licensing hub has produced recurring supervisory failures alongside genuine enforcement escalation and EU-funded institutional reform. Key deficiencies - Beneficial ownership register not publicly accessible (legitimate-interest access only, post-2022 CJEU ruling) - FATF Recommendations 6, 7 and 28 (targeted financial sanctions for TF/PF; DNFBP supervision) remain rated Partially Compliant - No registration framework for accountants and real estate agents as DNFBPs; low STR filing from notaries, CSPs, MVTS and real estate agents - Recurring AML/CFT control failures inside licensed EMI and crypto-asset firms despite a fast-expanding fintech sector Recent developments (18m) - OLAF-supported Lithuanian Customs raid (April 2025) on a company rerouting sanctioned EU-origin goods to Russia/Belarus via Central Asia - Lithuanian customs disclosed refusal of 28,854 sanctioned-goods export requests exploiting a 'medical exemption' loophole (reported June 2025) - Bank of Lithuania fined Pervesk UAB (Bankera-linked) €130,000 for AML/CFT control failures, with heightened supervision imposed (2025) - EU broadened the Belarus sanctions regime (December 2025) explicitly citing meteorological-balloon airspace incursions into Lithuania - MONEYVAL enhanced follow-up report (December 2024) upgraded Recommendation 2 to Compliant; Recommendations 6, 7, 28 remained Partially Compliant Law made at European Economic Area level that applies in Lithuania is covered once, on the [European Economic Area](/jurisdictions/eea/) page. This page covers Lithuania’s own layer: implementation, national authorities, national options and local enforcement. Brief ## Lead signal #### Lead Signal The defining development touching Lithuania this cycle is architectural rather than domestic: the European Union Council's sanctions package of 12 October 2026, which designated 743 individuals and 826 entities tied to Russia's military-industrial supply chain, is directly applicable across the bloc and therefore binds Lithuanian obliged entities without any national transposition step. Reporting describes this as the largest single expansion of the EU sanctions list since 2022, targeting suppliers of missile, drone and aircraft components. Lithuania's own implementation mechanism, run through the Ministry of Foreign Affairs, channels proposals into the EU process and carries autonomous Russia-regime measures into national application, but no Lithuania-specific Tier-1 implementing instrument for this particular package was independently retrieved this pass, so the finding rests on secondary sanctions-commentary sourcing layered onto a confirmed description of the standing implementation architecture. Read full brief #### Lead Signal The defining development touching Lithuania this cycle is architectural rather than domestic: the European Union Council's sanctions package of 12 October 2026, which designated 743 individuals and 826 entities tied to Russia's military-industrial supply chain, is directly applicable across the bloc and therefore binds Lithuanian obliged entities without any national transposition step. Reporting describes this as the largest single expansion of the EU sanctions list since 2022, targeting suppliers of missile, drone and aircraft components. Lithuania's own implementation mechanism, run through the Ministry of Foreign Affairs, channels proposals into the EU process and carries autonomous Russia-regime measures into national application, but no Lithuania-specific Tier-1 implementing instrument for this particular package was independently retrieved this pass, so the finding rests on secondary sanctions-commentary sourcing layered onto a confirmed description of the standing implementation architecture. Alongside the new designations, more than 3,000 existing Russia-related individual listings were extended to 22 September 2029, a housekeeping action that nonetheless locks in the EU's current sanctions architecture for a further three years and removes any near-term expiry pressure that might otherwise have prompted a review of individual listings. #### Other Developments A supervisory evaluation opened without a domestic finding attached. MONEYVAL formally launched its sixth-round mutual evaluation of Lithuania on 13-14 October 2026 in Vilnius, with the process reported to run to May 2028. This is a confirmed procedural fact about the evaluation cycle itself rather than a finding about Lithuania's current compliance posture, and it lands ahead of the EU's AML Regulation reaching full application on 10 July 2027 — meaning Lithuania's assessed framework and the bloc's harmonised regime will be in motion simultaneously over the coming evaluation window. A digital-asset population that did not move. The Bank of Lithuania's authorised population of crypto-asset service providers held steady at four authorisations plus two notifications under the relevant MiCA transitional provision, per the end-September interim register. No new Lithuanian authorisation or crypto-sanctions-evasion finding dated within this cycle's window was located, which keeps this a stability read rather than a development. #### Cross-Monitor Connections The EU Council's October designation package, aimed squarely at military-industrial supply chains supporting Russia, sits naturally alongside conflict-finance and state-capture work being tracked elsewhere: a listing of component suppliers is, in substance, a map of where sanctioned procurement networks have been routing money and goods, and that map is of direct interest to monitors tracking extractive-industry and conflict-adjacent financial flows. The sanctions-extension action, by locking in over 3,000 listings to 2029, also sets a multi-year horizon against which any future easing or tightening of the Russia regime elsewhere in the bloc can be measured. #### Outlook The MONEYVAL evaluation running to a reported May 2028 and the EU AML Regulation's full application on 10 July 2027 give Lithuania two overlapping and consequential dates to watch, with the Bank of Lithuania and the Financial Crime Investigation Service (FNTT) as the joint supervisory authorities whose practice will be tested against both. On sanctions, the near-term question is whether a Lithuania-specific Tier-1 implementing instrument for the 12 October package surfaces, which would convert the current probable-confidence, secondary-sourced finding into a confirmed domestic record; absent that, the architecture remains EU-directly-applicable with Lithuania's implementation role understood rather than individually evidenced this cycle. Earlier periodic briefs (7) 4 Nov 2026 · fim-2026-11-04 #### Lead Signal The defining development touching Lithuania is architectural rather than domestic: the European Union Council's sanctions package of 12 October 2026, which designated 743 individuals and 826 entities tied to Russia's military-industrial supply chain, is directly applicable across the bloc and therefore binds Lithuanian obliged entities without any national transposition step. Reporting describes this as the largest single expansion of the EU sanctions list since 2022, targeting suppliers of missile, drone and aircraft components. Lithuania's own implementation mechanism, run through the Ministry of Foreign Affairs, channels proposals into the EU process and carries autonomous Russia-regime measures into national application, but no Lithuania-specific Tier-1 implementing instrument for this particular package was independently retrieved this pass, so the finding rests on secondary sanctions-commentary sourcing layered onto a confirmed description of the standing implementation architecture. Alongside the new designations, more than 3,000 existing Russia-related individual listings were extended to 22 September 2029, a housekeeping action that nonetheless locks in the EU's current sanctions architecture for a further three years and removes any near-term expiry pressure that might otherwise have prompted a review of individual listings. #### Other Developments A supervisory evaluation opened without a domestic finding attached. MONEYVAL formally launched its sixth-round mutual evaluation of Lithuania on 13-14 October 2026 in Vilnius, with the process reported to run to May 2028. This is a confirmed procedural fact about the evaluation cycle itself rather than a finding about Lithuania's current compliance posture, and it lands ahead of the EU's AML Regulation reaching full application on 10 July 2027 — meaning Lithuania's assessed framework and the bloc's harmonised regime will be in motion simultaneously over the coming evaluation window. A digital-asset population that did not move. The Bank of Lithuania's authorised population of crypto-asset service providers held steady at four authorisations plus two notifications under the relevant MiCA transitional provision, per the end-September interim register. No new Lithuanian authorisation or crypto-sanctions-evasion finding dated within the window was located, which keeps this a stability read rather than a development. #### Cross-Monitor Connections The EU Council's October designation package, aimed squarely at military-industrial supply chains supporting Russia, sits naturally alongside conflict-finance and state-capture work being tracked elsewhere: a listing of component suppliers is, in substance, a map of where sanctioned procurement networks have been routing money and goods, and that map is of direct interest to monitors tracking extractive-industry and conflict-adjacent financial flows. The sanctions-extension action, by locking in over 3,000 listings to 2029, also sets a multi-year horizon against which any future easing or tightening of the Russia regime elsewhere in the bloc can be measured. #### Outlook The MONEYVAL evaluation running to a reported May 2028 and the EU AML Regulation's full application on 10 July 2027 give Lithuania two overlapping and consequential dates to watch, with the Bank of Lithuania and the Financial Crime Investigation Service (FNTT) as the joint supervisory authorities whose practice will be tested against both. On sanctions, the near-term question is whether a Lithuania-specific Tier-1 implementing instrument for the 12 October package surfaces, which would convert the current probable-confidence, secondary-sourced finding into a confirmed domestic record; absent that, the architecture remains EU-directly-applicable with Lithuania's implementation role understood rather than individually evidenced. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Lithuania has moved to a national sanctions posture that diverges from the European Union bloc-level position. On 14 October 2026 the Lithuanian government approved national asset freezes against Russian businessmen Alisher Usmanov and Mikhail Fridman, running to end-2027, after both men were removed from the EU sanctions list on 22 September 2026. Lithuania's Foreign Ministry had opposed the EU delisting, and Latvia and Estonia adopted comparable national measures in the same window. Under the FIM designation set, this is Comprehensive sanctions applied at the member-state level rather than the EU level, and it is a clear instance of a member state substituting national-list autonomy for a bloc-level removal it judged premature. Reporting on the decision rests on two Tier-2 outlets (LRT and Hromadske); no Lithuanian gazette text for the decision has been independently retrieved this cycle, so the underlying legal instrument is not yet directly cited here. Alongside the sanctions move, Lithuania's financial supervisor has been active on the enforcement side of its own regime. Lietuvos bankas revoked the electronic-money institution licence of Paytend Europe, UAB, a Chinese-owned payment firm, after an inspection identified serious and systematic violations in the monitoring of business relationships and transactions, including a failure to file suspicious transaction reports with the Financial Crime Investigation Service (FNTT). #### Other Developments Supervisory findings on recurring control gaps. Separately from the Paytend action, secondary reporting describes a Bank of Lithuania inspection programme for 2026 that prioritised AML/CTF, culminating in an August 2026 letter to heads of financial market participants flagging deficiencies in customer due diligence, record-keeping, internal controls, employee training and suspicious-transaction reporting as recurring enforcement risks. The same reporting states that FNTT recorded more than EUR 6.2 million in fines over the prior year, and that one electronic-money institution was barred from onboarding new customers and serving existing ones while an inspection was still running. This material is sourced to a single Tier-3 commentary synthesis; no Tier-1 publication of the underlying FNTT letter has been independently retrieved this cycle, so the figures and the characterisation of the letter should be read as probable rather than confirmed. Crypto-asset authorisation pipeline continues. Lietuvos bankas authorised Micar assets, UAB as a crypto-asset service provider under the Markets in Crypto-Assets Regulation, the fourth such authorisation issued in Lithuania. The authorisation permits custody and administration of clients' crypto-assets. This sits within a steady build-out of the supervised crypto perimeter following the full wind-down of Lithuania's pre-MiCA national registration regime from 1 January 2026. FATF follow-up re-rating. A FATF/MONEYVAL follow-up report shows Lithuania's Recommendation 2 re-rated from Partially Compliant to Compliant. Lithuania remains in enhanced follow-up, with no plenary grey-list action taken this cycle. Under the FIM designation set, Lithuania carries no FATF call-for-action or grey-list status, so neither Countermeasures nor Increased monitoring applies to it. #### Cross-Monitor Connections The Paytend licence revocation is a payments-regulation event with direct relevance to the World Payments Monitor's licensing and market-access tracking: an actively supervised fintech hub revoking a non-bank payment institution's authorisation for AML/CFT failure is a different signal from the same hub granting authorisations, and both are occurring in the same jurisdiction in the same period. The Micar assets authorisation is similarly a crypto/digital-asset event tracked in parallel by the crypto monitor's licensing module; the FIM reading foregrounds the AML/CTF supervisory dimension of that authorisation rather than the commercial or licensing-architecture dimension carried elsewhere. The national Usmanov/Fridman asset freeze, coordinated with Latvia and Estonia, is a sanctions-architecture development with potential relevance to any monitor tracking EU member-state divergence from bloc-level sanctions decisions, since it demonstrates that delisting at the EU level does not guarantee delisting at the national level in all member states. #### Outlook The durability of Lithuania's national sanctions position on Usmanov and Fridman through its stated end-2027 horizon will depend on whether other EU member states beyond Latvia and Estonia adopt parallel measures, and on whether the European Union itself revisits the September 2026 delisting. Confirmation of the underlying gazette text for the national freeze, not yet retrieved this cycle, would raise the evidentiary basis for this finding from Tier-2 corroboration to a primary-source footing. On the supervisory side, the pattern of recurring CDD, record-keeping and reporting deficiencies flagged by Bank of Lithuania's 2026 inspection programme, combined with the Paytend revocation, points to continued active enforcement against payment and e-money institutions rather than a settled baseline; further supervisory action against other obliged entities identified in that inspection round would be consistent with this trajectory. The crypto-asset authorisation pipeline is expected to continue on its current pace absent a change in Lietuvos bankas's posture, which the FATF Recommendation 2 re-rating does not by itself constrain. 12 Oct 2026 · fim-2026-10-12 #### Lead Signal The Bank of Lithuania has publicly clarified a narrow statutory boundary within its Article 73 supervisory architecture, confirming that the mere continuing presence of a Russian banking licence held by a parent group does not, by itself, constitute grounds for supervisory measures against the Lithuanian-incorporated subsidiary. The clarification, reported on 8 October 2026 and concerning SEB bank, speaks to the limits of national sanctions-adjacent supervisory tools when the triggering fact sits at the parent-group level rather than in the conduct of the licensed entity itself. This is best read as architecture, not incident: a central bank articulating where its own enabling statute does and does not reach, rather than any active enforcement step against the institution in question. The clarification matters less for what it does than for what it withholds. Article 73 is Lithuania's domestic lever for responding to parent-level exposure to sanctioned or adversarial jurisdictions, and a regulator narrowing its own reach is itself a disclosure about the shape of the regime. Absent a parallel EU or national sanctions designation reaching the Russian-licensed entity directly, Lithuanian supervisors are signalling that structural ownership links to Russia-licensed banking operations do not, standing alone, cross the threshold that would compel action against the EU-regulated subsidiary. #### Other Developments No material movement was identified this cycle across beneficial ownership, enabler-jurisdiction exposure, conflict finance, crypto/digital-asset AML perimeter questions, compliance technology, the standing AML/CTF regime, or commercial activity. The standing regime continues to rest on the Law on the Prevention of Money Laundering and Terrorist Financing, with the FNTT as financial intelligence unit and the Bank of Lithuania as supervisor of licensed entities; Lithuania remains in MONEYVAL's enhanced follow-up process after its December 2018 fifth-round mutual evaluation, most recently re-rated in the fourth enhanced follow-up report adopted 15 December 2023. #### Cross-Monitor Connections The Article 73 clarification sits adjacent to payments-sector supervisory activity tracked separately: the Bank of Lithuania's broader posture toward electronic money institutions, including a prior temporary prohibition on an electronic money institution providing services to new and existing customers while an inspection proceeded, reflects a supervisor willing to act on firm-specific conduct even as it declines to extend Article 73 to parent-group ownership facts alone. Where sanctions-exposure questions intersect with licensed payment and banking entities operating in Lithuania, the distinction the Bank of Lithuania has drawn here—between what a parent group does elsewhere and what the supervised entity itself does in Lithuania—will likely recur as a reference point. #### Outlook The durability of this clarification as a precedent depends on whether a Bank of Lithuania primary notice or decision eventually corroborates the press-reported position; at present the sourcing is institutional-quote-via-press rather than a primary regulatory publication, so the finding should be treated as probable rather than confirmed pending fuller substantiation. Should EU-level sanctions architecture evolve to reach parent-group banking licences more directly, this narrow domestic gateway could be narrowed further or bypassed entirely by a supranational designation. 6 Oct 2026 · fim-2026-10-06 #### Lead Signal Lithuania's anti-money-laundering framework illustrates, this cycle, a structural feature of EU-member regimes that is easy to overlook when attention is fixed on domestic legislative calendars: the enhanced due diligence perimeter can expand without any domestic legislative act at all. The Law on the Prevention of Money Laundering and Terrorist Financing (No VIII-275), in its article 14(1)(3), requires enhanced due diligence toward customers and beneficial owners connected to jurisdictions named on the European Commission high-risk third-country list, and because that reference is a live incorporation rather than a fixed schedule, the Commission's own updates propagate directly into Lithuanian obliged-entity obligations. Commission Delegated Regulations 2026/46 and 2026/83 added Russia, Bolivia and the British Virgin Islands to that list, with Russia's listing taking effect from 29 January 2026; the preceding Delegated Regulation 2025/1184 had already reshaped the list's composition, adding ten jurisdictions including Algeria, Kenya, Lebanon and Venezuela while removing eight others, among them Panama, the Philippines and the UAE. Lithuanian obliged entities inherit each of these changes automatically. The architectural point is sharpened by the fact that Lithuanian law maintains a second, independent EDD trigger. Article 14(1)(4) of the same law requires enhanced due diligence for customers or beneficial owners connected to jurisdictions identified by the Financial Action Task Force as high-risk, a determination that runs on its own track and need not align with the Commission list. A jurisdiction can therefore be high-risk for Lithuanian EDD purposes under one basis and not the other, and firms operating in Lithuania must monitor both lists rather than treating them as a single combined feed. #### Other Developments Remote identification is governed by a closed, exhaustive list of routes. Article 11(1) of the AML Law permits establishing customer and beneficial-owner identity without physical presence only through one of five defined mechanisms: reliance on a third party under article 13, an EU electronic identification scheme at high or substantial assurance level, a qualified electronic signature, live video capturing the original identity document together with an advanced electronic signature or a captured face image, or a first payment from the customer's own account at a qualifying EU or equivalent credit, payment or e-money institution accompanied by a certified paper copy of the identity document. An asynchronous onboarding journey built around document upload plus a selfie check is not independently compliant under Lithuanian law; it must be structurally mapped onto one of these five routes before it can be relied upon. The precise wording of the five limbs rests on an unverified translation, and further local-language confirmation would be needed before this reading is treated as settled in all its particulars. Low-risk electronic money attracts a bounded customer due diligence derogation. Articles 9(4) and 9(5) of the AML Law permit credit and e-money institutions, where their own risk assessment and management procedures establish low money-laundering or terrorist-financing risk, to depart from the standard identification requirements of articles 10 to 12 for non-reloadable e-money instruments with stored value capped at EUR 150, restricted to goods-and-services use, with no anonymous funding and no cash redemption. Article 9(5) separately permits opening an account on limited data, with full identification completed within one month, subject to ongoing monitoring obligations. Lithuanian law does not carry a separate EUR 50 remote-payment limb that appears in some comparator regimes; the derogation is built around the EUR 150 non-reloadable instrument alone. Record retention for customer due diligence material runs to eight years. Articles 19(10) and 19(11) require that registration log data, in paper or electronic form, be kept for eight years from the end of the transaction or business relationship, with shorter five-year periods applying to certain correspondence. This retention period sits at the longer end of what comparator jurisdictions apply to equivalent material, with implications for data-minimisation planning by firms operating across multiple EU markets with differing retention floors. #### Cross-Monitor Connections The automatic incorporation mechanism under article 14(1)(3) is the kind of structural finding that routes naturally to other monitors tracking EU-level list governance: any future Commission delegated regulation altering the high-risk third-country list will, by the same mechanism, alter obligations across every EU member state simultaneously, making the Commission's own listing process a more consequential single point of regulatory change than any one member state's domestic legislative calendar. Where other monitors track sanctions-list or conflict-finance exposure tied to jurisdictions newly added to the Commission's high-risk list, the Lithuanian incorporation mechanism demonstrates concretely how such a listing decision converts into binding firm-level EDD obligations across the bloc without further domestic process, a pattern worth cross-referencing wherever a newly-listed jurisdiction's financial exposure through EU-domiciled correspondent or payment channels is being assessed. #### Outlook The most immediate open question for Lithuania is the transposition status of the sixth Anti-Money Laundering Directive and the jurisdiction's alignment timeline with the directly-applicable AML Regulation and the Anti-Money Laundering Authority build-out; this was not established in the present research cycle and remains a gap. Until that timeline is confirmed, Lithuania's AML Law No VIII-275 continues to operate as the operative national instrument, with the Commission high-risk third-country list and FATF findings as its two live external EDD triggers. Firms with Lithuanian exposure should expect the EDD perimeter to continue moving in step with future Commission delegated regulations rather than with any domestic legislative schedule, and should treat the article 11(1) remote-identification list as closed rather than illustrative when designing or auditing onboarding journeys. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal The Bank of Lithuania's own supervisory letter, based on 2025 supervisory data and ten AML/CTF inspections, now characterises Lithuania's dual identity as the EU's leading electronic-money-institution and payment-institution licensing hub, and as a historically high-volume virtual-asset-service-provider registration jurisdiction, as a structural supervisory risk factor rather than a settled strength. The letter flags weak enhanced due diligence, disproportionately low suspicious-transaction-report volume, incomplete sanctions screening, and a need to verify authorisation under MiCAR among obliged entities. This recharacterisation is corroborated by two 2026 AML/CTF enforcement fines against Lithuanian-licensed financial institutions: a €270,000 fine against European Merchant Bank (EMBank) for anti-money-laundering, counter-terrorist-financing and sanctions-control shortcomings, and a €290,000 fine against Walletto UAB, an electronic money institution, for internal-controls failures and inadequate information provision to the regulator. #### Other Developments Verified Payments capital-adequacy restriction. The Bank of Lithuania has ordered electronic money institution Verified Payments to restore capital adequacy by 1 October 2026, and pending a further decision has barred it from taking new clients, encumbering assets, or lending. This sits alongside the two enforcement fines as a third concurrent supervisory action against a Lithuanian-licensed payment entity within 2026, reinforcing the pattern the supervisory letter itself describes. MiCA VASP-to-CASP transition dating dispute. Secondary sources report conflicting transitional deadlines for Lithuania's virtual-asset-service-provider population converting to full Markets in Crypto-Assets Regulation authorisation: a 1 January 2026 national extension against MiCA Article 143(3)'s EU-wide backstop reported as no later than 1 July 2026. Which date actually governs Lithuania's cut-off has not been reconciled against primary implementing law this cycle, and the Bank of Lithuania's own supervisory letter separately flags the need to verify CASP authorisation among obliged entities, indicating this uncertainty has practical supervisory consequences rather than being a purely academic dating question. MONEYVAL 6th round evaluation approaching. Lithuania's sixth-round mutual evaluation by MONEYVAL is reported to start in October 2026, arriving at a moment when the country's own supervisory authority has just documented material AML/CTF deficiencies among obliged entities, a timing coincidence that raises the stakes of the evaluation's findings. #### Cross-Monitor Connections The capital-adequacy restriction against Verified Payments and the underlying supervisory-letter findings connect directly to the world-payments monitor's tracking of Lithuania's electronic-money-institution and payment-institution sector, where the same entity and the same Bank of Lithuania supervisory posture are tracked from a market-structure and legal-risk perspective rather than an AML/CTF-compliance perspective; the two monitors are describing the same underlying supervisory tightening from different analytical angles. The MiCA CASP-transition dating dispute similarly connects to the crypto monitor's tracking of Lithuania's crypto-licensing regime, where the same disputed backstop date and the same low legacy-VASP conversion rate are analysed from a licensing-perimeter rather than an AML/CTF-compliance perspective. #### Outlook The MONEYVAL 6th round evaluation, starting October 2026, is the clearest near-term marker of how the international AML/CTF community will assess Lithuania's regime against the backdrop of its own supervisory authority's self-identified deficiencies. Separately, the European Banking Authority's draft reporting framework will determine, via a 31 December 2026 reference date, which Lithuanian payment institutions and electronic money institutions face direct supervision by the EU's Anti-Money Laundering Authority from 2027 rather than purely national Bank of Lithuania supervision — a structural shift in the supervisory perimeter that will interact directly with the deficiencies the Bank of Lithuania has itself just identified. 11 Sep 2026 · fim-2026-08-21 #### Lead Signal Lithuania's crypto-asset supervisory perimeter has completed its migration from light-touch VASP registration to binding MiCA CASP authorisation, with the Bank of Lithuania now the competent authority and actively issuing authorisations to individual applicants. This consolidates an estimated cohort of roughly 370 previously-registered virtual-asset service providers into a single, harmonised EU licensing gateway, closing a grandfathering window that had run into 2026. The transition materially raises the compliance bar for firms that had operated under the prior, lighter FCIS-run VASP regime, since CASP authorisation carries EU-wide passporting rights but also the full weight of MiCA governance, prudential and conduct requirements. #### Other Developments Standardised inspection templates. The Bank of Lithuania's 2026 inspection plan includes, for the first time, standardised AML/CTF inspection templates, an incremental but structurally meaningful supervisory-technology development. This signals a move toward more consistent, comparable supervisory outputs across obliged entities rather than ad hoc examination practice, and it sits alongside continued enhancement of the Bank of Lithuania's broader supervisory toolkit. AML/CTF regime continuity. Lithuania's AML/CTF framework continues to rest on the Law on the Prevention of Money Laundering and Terrorist Financing, with the Financial Crime Investigation Service (FCIS) as supervisor and financial intelligence unit. Lithuania remains under MONEYVAL's enhanced follow-up procedure since its 2018 mutual evaluation, but this cycle records incremental progress, including a re-rating of the supervision-related recommendation to largely-compliant, evidence of a jurisdiction implementing a risk-based AML/CFT supervision reform rather than standing still under review. #### Cross-Monitor Connections The Bank of Lithuania's interim restriction on an electronic money institution over suspected AML/CFT deficiencies is a matter that touches the payments-supervision perimeter as much as the AML/CFT regime itself; the underlying supervisory action is the same fact set that the World Payments Monitor's licensing and market-access tracking would recognise as part of the Bank of Lithuania's concurrent growth-enabling and risk-based enforcement activity this cycle. Similarly, the completed MiCA CASP transition is the same underlying development that a digital-asset-focused monitor would read primarily through the lens of licensing architecture rather than financial-crime supervision; here the emphasis is on what the CASP gateway means for the integrity of the crypto-asset service-provider population now brought fully within a binding EU authorisation and passporting regime. #### Outlook Watch for the AMLA's finalisation of technical standards on AML/CFT supervisory-college functioning under AMLD6, due by 10 July 2026, which will shape how Lithuania's FCIS cooperates with counterpart supervisors once transposed. Watch also for the resolution of the interim restriction on the affected electronic money institution, since its outcome, whether remediation, further sanction, or licence action, will be the clearest near-term signal of how firmly the Bank of Lithuania is prepared to act on AML/CFT deficiencies identified through its enhanced supervisory posture. The structural direction across both the crypto-asset and payments-adjacent AML/CTF perimeters is toward tighter, more standardised, technology-enabled supervision. 11 Aug 2026 · fim-2026-08-05 #### Lead Signal Lithuania's Bank of Lithuania has concluded a concentrated enforcement wave against the country's electronic-money-institution and payment-institution sector, imposing five separate AML/CTF fines within recent months: UAB ConnectPay (EUR 110,000, for failures in customer identification, PEP identification and risk assessment), MisterTango UAB (EUR 245,000, its third sanction since 2016, with activities restricted as a preventive measure), UAB Pervesk (EUR 244,000, with a mandated remediation plan and a temporary prohibition on serving high-risk customers), Walletto UAB (EUR 290,000, for internal-control and information-provision failures), and European Merchant Bank UAB (EUR 270,000, for AML/CTF shortcomings). Assessed with high confidence, this cluster exposes structural, not merely episodic, weaknesses in customer due-diligence and PEP-screening controls across Lithuania's EMI/PI population. The repeat-offender status of MisterTango, sanctioned three times since 2016, is the most analytically significant element: it signals that supervisory pressure alone has not durably closed the underlying control gap for at least one licensed entity. The concentration of enforcement in this specific sector is plausibly explained by Lithuania's status as one of the EU's largest per-capita EMI/PI licensing hubs, meaning enforcement volume may track population size and supervisory intensity rather than indicating a permissive underlying culture — an enablement-theory reading that must be held alongside the more straightforward reading of a structural control-gap cluster. #### Other Developments Sanctions architecture escalation. Lithuania's Financial Crime Investigation Service (FNTT) reports an assessed EUR 6.2 million in fines and 232 suspicion-of-sanctions-evasion referrals, of which 77 were analysed in detail, concentrated chiefly on vehicle-export and origin-concealment schemes routed toward Russia and Belarus. This is corroborated only by a single tier-three source, though directionally supported by separate reporting on an adjacent Ministry of Foreign Affairs proposal. That Ministry proposal would expand national sanctions to include new restrictions on property purchases near strategic sites and entry bans for Russian and Belarusian cultural, entertainment and sports figures perceived as supporting the war in Ukraine — a national-level layering exercise sitting atop the EU's own Council sanctions packages. Crypto-asset supervisory transition. Lithuania's VASP-to-CASP transition is now complete: the national VASP registration regime, previously supervised by the Financial Crime Investigation Service on a lighter-touch registration basis, ended on 1 January 2026 and has been replaced by Bank of Lithuania authorisation of crypto-asset service providers under the Law on Markets in Crypto-Assets, implementing MiCA. This is assessed as a clean structural supersession rather than an incremental adjustment, consolidating crypto-asset supervision under a single prudential authority. Compliance-technology posture. The Bank of Lithuania introduced dedicated fintech supervisory contact points on 7 April 2026, a high-confidence, Tier-1-sourced development that signals a proactive engagement posture running in parallel with the inspection-based enforcement described above. This sits against a backdrop of continued scale growth in CENTROlink, Lithuania's payments infrastructure, which processed 379.7 million payments in 2025, up 28.9 percent year over year, with 68 percent of all Lithuanian payments now processed instantly — scale growth that raises the stakes for supervisory capacity and RegTech adoption alike. #### Cross-Monitor Connections The EMI/PI enforcement wave described above sits squarely at the intersection of financial-integrity and payments-market analysis: the same population of Lithuanian-licensed electronic-money institutions and payment institutions under AML/CTF supervisory pressure here is also the subject of licensing, conduct and market-access tracking in the payments-monitor register, and the two lenses should be read together rather than in isolation. The sanctions-evasion enforcement caseload, concentrated on vehicle-export and origin-concealment schemes toward Russia and Belarus, is a conflict-finance-adjacent signal worth flagging for cross-reference with commodity- and trade-flow monitoring, given the trade-finance customer typology involved. No state-capture or information-operations signal was independently evidenced this cycle. #### Outlook The near-term picture for Lithuania is one of continuing supervisory pressure on the EMI/PI sector, with the open question being whether the Bank of Lithuania's new fintech dialogue mechanism reduces the recurrence of enforcement action or simply runs in parallel with it. The repeat-sanction pattern at MisterTango is the single most important indicator to track next cycle: a fourth sanction would sharpen the read toward a durable, unresolved control gap rather than a converging one. On the sanctions-evasion side, confirmation of the Ministry of Foreign Affairs' proposed national sanctions expansion, and any further detail on the statutory basis for the FNTT's reported EUR 6.2 million enforcement caseload, would materially firm up assessed-confidence judgments currently resting on single-source reporting. Domain intelligence (D1–D8) #### Sanctions Lithuania's decision on 14 October 2026 to impose a national asset freeze on Alisher Usmanov and Mikhail Fridman, following their removal from the European Union sanctions list on 22 September 2026, is a structural sanctions-architecture development rather than an incident. Under the FIM designation set it is categorised as Comprehensive sanctions applied at national rather than EU level. The Lithuanian Foreign Ministry's public opposition to the EU delisting, and the parallel adoption of national measures by Latvia and Estonia, show this was a coordinated regional response among the Baltic states rather than an isolated Lithuanian decision. The measure is stated to run to end-2027. Continue reading This divergence matters architecturally because it demonstrates that an EU-level sanctions delisting does not automatically produce uniform relief across the bloc: a member state retains the capacity to substitute a national asset freeze for a removed EU listing where it judges the underlying risk unresolved. For firms operating across Lithuania, Latvia and Estonia, this means screening against EU consolidated lists alone would, in this instance, have missed an active and enforceable restriction in three member states. The evidentiary basis for this finding currently rests on two Tier-2 outlets (LRT, Hromadske) reporting consistently on the same set of facts; no Lithuanian national gazette or legal-instrument text has been independently retrieved this cycle to confirm the precise legal mechanism (national regulation versus government decree) underpinning the freeze. No other sanctions-related development for Lithuania was identified this cycle. The national asset freeze stands as the single, material sanctions-architecture signal, and its significance lies less in the two named individuals than in what it reveals about the durability — or lack of durability — of EU-level delisting decisions at the member-state level. #### Outlook The principal open question is whether the Lithuanian national freeze will be formalised in a gazetted legal instrument that can be independently verified, and whether other EU member states beyond Latvia and Estonia will adopt similar national measures in response to the same September 2026 delisting. Firms with exposure in the Baltic states should treat EU-list screening as a floor rather than a ceiling for sanctions coverage in this jurisdiction cluster while the national measures remain in force through their stated end-2027 horizon. #### Enabler Jurisdictions Lietuvos bankas's revocation of Paytend Europe, UAB's electronic-money institution licence is a material data point against any characterisation of Lithuania's fintech hub as an enabler jurisdiction in the permissive sense. The inspection underlying the revocation identified serious and systematic violations in the monitoring of business relationships and transactions, and the firm — Chinese-owned — failed to file suspicious transaction reports with FNTT. This is an instance of a licensing authority actively removing market access from a non-bank payment institution for AML/CFT failure, which is the architecture-over-incident signal that distinguishes an enforcement-active hub from one that enables illicit flows through inaction. Continue reading The revocation sits alongside a broader pattern described in secondary reporting: a 2026 Bank of Lithuania inspection programme that prioritised AML/CTF, an August 2026 supervisory letter to heads of financial market participants on recurring control deficiencies, and a separate electronic-money institution barred from onboarding mid-inspection. Taken together, these signals support a reading of Lithuania's payment-institution and e-money sector as one under active supervisory pressure rather than one left to self-regulate. The FIM analytical principle that absence of enforcement in a permissive jurisdiction is itself a finding cuts the other way here: the presence of visible, licence-level enforcement action against a payment institution is the more significant signal for Lithuania's current enabler-jurisdiction standing. The evidentiary basis differs by claim: the Paytend revocation itself is Tier-1 sourced directly from Lietuvos bankas. The broader pattern of recurring deficiencies and the EUR 6.2 million fine total rest on a single Tier-3 commentary synthesis, with no independently retrieved Tier-1 publication of the underlying FNTT letter this cycle. #### Outlook Whether this enforcement activity extends to further licence actions against other payment or e-money institutions identified in the 2026 inspection round, beyond Paytend, is the key open question for Lithuania's enabler-jurisdiction standing going forward. A primary-source publication of the FNTT August 2026 letter would materially strengthen the evidentiary basis for the broader pattern currently resting on secondary reporting. #### Crypto / Digital Assets / Financial Innovation Lietuvos bankas's authorisation of Micar assets, UAB as a crypto-asset service provider under the Markets in Crypto-Assets Regulation — the fourth such authorisation issued in Lithuania — continues a steady, structural build-out of the country's supervised crypto perimeter. The authorisation permits custody and administration of clients' crypto-assets, placing a previously unregulated activity class within a licensed and supervised regime. This development follows the full wind-down of Lithuania's pre-MiCA national crypto registration regime from 1 January 2026, meaning that as of this cycle only MiCA-authorised entities may lawfully provide crypto-asset services in the jurisdiction — a clean architectural transition from a lighter national regime to a fully harmonised EU one, with no parallel legacy track remaining open. Continue reading From a financial-integrity perspective, the significance of this cycle's single authorisation lies less in the individual firm than in the structural continuity it represents: Lithuania has neither accelerated nor slowed its CASP authorisation pace, and the legacy-regime wind-down removes a potential supervisory gap that could otherwise have been exploited during a transitional period. No crypto-specific enforcement action, typology observation, or illicit-finance nexus was identified for Lithuania this cycle; the finding here is purely one of licensing architecture. The claim is Tier-1 sourced directly to Lietuvos bankas's own publication of the authorisation, giving this finding a stronger evidentiary footing than several of the other developments in this cycle's Lithuania coverage. #### Outlook Continued CASP authorisation activity at a similar pace would be consistent with the current trajectory. The more significant forward-looking question for this domain is whether Lithuania's active AML/CTF supervisory posture, visible in the Paytend enforcement action, extends in a future cycle to scrutiny of a crypto-asset service provider rather than remaining concentrated in the payment-institution sector. Cumulative analysis D5 Crypto / Digital Assets / Financial Innovation Cumulative analysis · cross-cycle historical This is the first cumulative synthesis for the crypto, digital assets and financial innovation domain in Lithuania, integrating the baseline evidence into a single state-of-the-domain reading. The licensed electronic-money-institution and crypto-asset sector of Lithuania is the clearest financial-innovation signal in this baseline, and it is a mixed one: recurring supervisory enforcement against genuine control failures, running alongside a structural pattern of repeated failure across multiple licensed firms. The Bank of Lithuania fined Pervesk UAB, a Bankera-affiliated entity, EUR130,000 and imposed heightened supervision after finding the firm had failed to properly assess high-risk client and institutional risk, had not adapted its transaction-monitoring scenarios to its actual risk profile, and had provided insufficient AML training to staff. This sits within a wider pattern described as gross, systematic compliance failures recurring across Payeer, Transactive Systems and Payrnet, a pattern that persisted despite a 2022-2024 EU-funded Technical Support Instrument project specifically intended to strengthen the risk-based AML/CFT supervisory capacity of Lithuania, including development of a VASP sectoral risk methodology. This baseline synthesis assesses, at moderate confidence, that the fintech and VASP licensing growth of Lithuania continues to outpace supervisory capacity despite genuine reform investment, treating this as a structural rather than merely episodic control gap. The sanctions-evasion dimension of this sector is separately significant and carried forward as a distinct thread of this synthesis. Payeer, a Lithuania-licensed crypto firm, received a record fine in 2024 for enabling transfers from EU-sanctioned Russian banks to be converted into ruble-denominated crypto-wallet transactions, a scheme the active-scheme inventory captures through an on-chain-observable red-flag indicator. This finding sits at the intersection of the licensed-sector supervisory strain of Lithuania and the broader EU sanctions-architecture perimeter, since the 19th EU sanctions package specifically extended measures to crypto-asset providers connected to the Russian financial messaging system, meaning Lithuania-licensed VASPs sit within an expanding compliance perimeter that both EU sanctions design and domestic AML supervision are converging on simultaneously. Structural mitigants are in motion but not yet realised, and this baseline records both sides honestly. The EU Anti-Money Laundering Authority is planned to begin direct supervision of approximately 40 high-risk cross-border obliged entities from 2028, a cohort assessed as potentially including Lithuania-domiciled EMI and VASP firms given their cross-border footprint, which would shift the supervisory perimeter for the largest firms from purely national Bank of Lithuania oversight toward a hybrid EU-level regime. Ahead of that transition, the Financial Crime Investigation Service of Lithuania has already completed its own EU-funded capacity-building project, indicating domestic supervisory investment running in parallel with, rather than waiting for, the EU-level build-out. This period also brackets the point at which the EU Markets in Crypto-Assets Regulation reached full application from January 2025, reshaping licensing expectations for crypto-asset service providers ahead of the crypto-priority supervisory plans of AMLA, meaning firms already navigating MiCA authorisation face converging rather than sequential obligations as the AMLA horizon approaches. An open evidentiary question is carried forward in this synthesis: independent corroboration, beyond the single OCCRP source, of the Pervesk and Bankera enforcement narrative and its current remediation status has not been obtained this cycle, a caveat that matters because it determines whether the heightened-supervision order of the Bank of Lithuania should be read as an ongoing containment measure or a closed matter. The recurrence of enforcement action across four separate licensed entities, Pervesk and Bankera, Payeer, Transactive Systems, and Payrnet, over a period spanning the very years the EU-funded supervisory-capacity project was active, is itself a data point about the pace at which reform can outstrip a rapidly growing licensing population, rather than a simple indictment of the reform effort. Looking forward, the near-term watch items for this domain are the continued institutional build-out of AMLA, including a July 2026 public hearing on ongoing-monitoring guidelines directly relevant to VASP and EMI supervisory expectations, and the 2028 direct-supervision start date, whose entity-selection methodology has not yet been published. Until that methodology clarifies which Lithuania-domiciled firms fall within the initial cohort of approximately forty entities, the domestic enforcement pattern of repeated fines against individual licensed firms is assessed as likely to remain the primary visible signal of control weakness in this sector, even as the structural AMLA transition proceeds in parallel. This synthesis will integrate, rather than append, any further enforcement actions, remediation confirmations, or AMLA selection-methodology developments in subsequent cycles. Cumulative analysis This is the first cumulative synthesis for the crypto, digital assets and financial innovation domain in Lithuania, integrating the baseline evidence into a single state-of-the-domain reading. The licensed electronic-money-institution and crypto-asset sector of Lithuania is the clearest financial-innovation signal in this baseline, and it is a mixed one: recurring supervisory enforcement against genuine control failures, running alongside a structural pattern of repeated failure across multiple licensed firms. The Bank of Lithuania fined Pervesk UAB, a Bankera-affiliated entity, EUR130,000 and imposed heightened supervision after finding the firm had failed to properly assess high-risk client and institutional risk, had not adapted its transaction-monitoring scenarios to its actual risk profile, and had provided insufficient AML training to staff. This sits within a wider pattern described as gross, systematic compliance failures recurring across Payeer, Transactive Systems and Payrnet, a pattern that persisted despite a 2022-2024 EU-funded Technical Support Instrument project specifically intended to strengthen the risk-based AML/CFT supervisory capacity of Lithuania, including development of a VASP sectoral risk methodology. This baseline synthesis assesses, at moderate confidence, that the fintech and VASP licensing growth of Lithuania continues to outpace supervisory capacity despite genuine reform investment, treating this as a structural rather than merely episodic control gap. The sanctions-evasion dimension of this sector is separately significant and carried forward as a distinct thread of this synthesis. Payeer, a Lithuania-licensed crypto firm, received a record fine in 2024 for enabling transfers from EU-sanctioned Russian banks to be converted into ruble-denominated crypto-wallet transactions, a scheme the active-scheme inventory captures through an on-chain-observable red-flag indicator. This finding sits at the intersection of the licensed-sector supervisory strain of Lithuania and the broader EU sanctions-architecture perimeter, since the 19th EU sanctions package specifically extended measures to crypto-asset providers connected to the Russian financial messaging system, meaning Lithuania-licensed VASPs sit within an expanding compliance perimeter that both EU sanctions design and domestic AML supervision are converging on simultaneously. Structural mitigants are in motion but not yet realised, and this baseline records both sides honestly. The EU Anti-Money Laundering Authority is planned to begin direct supervision of approximately 40 high-risk cross-border obliged entities from 2028, a cohort assessed as potentially including Lithuania-domiciled EMI and VASP firms given their cross-border footprint, which would shift the supervisory perimeter for the largest firms from purely national Bank of Lithuania oversight toward a hybrid EU-level regime. Ahead of that transition, the Financial Crime Investigation Service of Lithuania has already completed its own EU-funded capacity-building project, indicating domestic supervisory investment running in parallel with, rather than waiting for, the EU-level build-out. This period also brackets the point at which the EU Markets in Crypto-Assets Regulation reached full application from January 2025, reshaping licensing expectations for crypto-asset service providers ahead of the crypto-priority supervisory plans of AMLA, meaning firms already navigating MiCA authorisation face converging rather than sequential obligations as the AMLA horizon approaches. An open evidentiary question is carried forward in this synthesis: independent corroboration, beyond the single OCCRP source, of the Pervesk and Bankera enforcement narrative and its current remediation status has not been obtained this cycle, a caveat that matters because it determines whether the heightened-supervision order of the Bank of Lithuania should be read as an ongoing containment measure or a closed matter. The recurrence of enforcement action across four separate licensed entities, Pervesk and Bankera, Payeer, Transactive Systems, and Payrnet, over a period spanning the very years the EU-funded supervisory-capacity project was active, is itself a data point about the pace at which reform can outstrip a rapidly growing licensing population, rather than a simple indictment of the reform effort. Looking forward, the near-term watch items for this domain are the continued institutional build-out of AMLA, including a July 2026 public hearing on ongoing-monitoring guidelines directly relevant to VASP and EMI supervisory expectations, and the 2028 direct-supervision start date, whose entity-selection methodology has not yet been published. Until that methodology clarifies which Lithuania-domiciled firms fall within the initial cohort of approximately forty entities, the domestic enforcement pattern of repeated fines against individual licensed firms is assessed as likely to remain the primary visible signal of control weakness in this sector, even as the structural AMLA transition proceeds in parallel. This synthesis will integrate, rather than append, any further enforcement actions, remediation confirmations, or AMLA selection-methodology developments in subsequent cycles. domain_sub_briefs · D5 · Cumulative analysis Standing baseline position MiCA CASP authorisation is the exclusive gateway for LT crypto-asset service providers; Bank of Lithuania has begun issuing CASP authorisations, replacing the former FCIS-run VASP registration model. Bank of Lithuania granted its fourth MiCA CASP authorisation to Micar assets, UAB on 3 March 2026. Periodic updates (3) 28 Sep 2026 · fim-2026-09-28 #### Crypto / Digital Assets / Financial Innovation For Lithuania specifically, the crypto and digital-asset integrity question this cycle centres on the disputed transitional deadline governing when Lithuania's previously nationally-registered virtual-asset service providers must complete conversion to full Markets in Crypto-Assets Regulation authorisation as crypto-asset service providers. Secondary sources report two competing dates: a 1 January 2026 national extension, and MiCA's own Article 143(3) EU-wide backstop, reported as no later than 1 July 2026. Which date actually governs Lithuania's cut-off has not been reconciled against primary implementing law this cycle, and this is recorded as a genuinely disputed state of the record rather than a settled fact in either direction. The practical significance of this dating dispute is sharpened by the Bank of Lithuania's own supervisory letter, which separately flags a need to verify MiCAR authorisation among obliged entities — indicating the regulator itself regards the authorisation-perimeter question as live and unresolved, not merely a matter of secondary-source imprecision. Given Lithuania's historically high volume of VASP registrations, an unresolved authorisation perimeter of this kind has direct AML/CTF relevance: an unauthorised entity that has fallen out of the registered/authorised perimeter, whichever backstop date applies, is by definition outside the compliance and reporting obligations the licensing regime is meant to enforce. #### Outlook Reconciliation of the exact backstop date against Lithuania's own implementing legislation is the clearest single item that would resolve this uncertainty. Until that reconciliation occurs, the AML/CTF exposure of any entities operating in the gap between the two reported dates should be treated as an open question rather than assumed to be immaterial. #### Compliance Technology and Active Defence The compliance-technology and active-defence posture of Lithuania this cycle is the most structurally clear of the six domains: a completed domestic capacity-building project sits directly ahead of an EU-level supervisory build-out that will eventually reach the same firms. The Financial Crime Investigation Service completed a 2022-2024 EU-funded Technical Support Instrument project that strengthened risk-based AML/CFT supervision domestically, including the development of a VASP sectoral risk methodology, a concrete deliverable directly relevant to the recurring EMI and crypto control failures identified elsewhere in the evidence for this cycle, since a sectoral risk methodology is precisely the kind of supervisory tool that could, if applied consistently, have identified the risk-assessment and monitoring-scenario deficiencies later found at Pervesk UAB. Continue reading At the EU level, the Anti-Money Laundering Authority continues its institutional build-out, including a scheduled July 2026 public hearing on ongoing-monitoring guidelines, a near-term signal on supervisory expectations that will directly affect Lithuania-domiciled obliged entities once finalised. This sits ahead of the planned 2028 direct-supervision start of AMLA for approximately 40 high-risk cross-border obliged entities, a cohort assessed as potentially including Lithuania-domiciled EMI and VASP firms given their cross-border footprint. The structural significance here is that the domestic supervisory-capacity investment of Lithuania, the completed FCIS project, and the EU-level build-out of AMLA are proceeding as parallel, complementary tracks rather than a single national reform sequence, meaning the compliance-technology posture of Lithuania is currently strengthening on two fronts simultaneously, national and supranational, even though neither track has yet fully closed the control gaps visible in the enforcement record. This dual-track build-out should be read against the backdrop of the three-instrument EU AML Package: the directly applicable AML Regulation, Regulation (EU) 2024/1624, effective 10 July 2027, the sixth AML Directive requiring national transposition, with the transposition vehicle and date for Lithuania not yet specified, and the AMLA Regulation, Regulation (EU) 2024/1620, establishing the Authority itself. The supervisory perimeter of AMLA is a hybrid one by design: it will not replace national supervision by the Bank of Lithuania and the Financial Crime Investigation Service wholesale, but will instead directly supervise a defined high-risk cross-border cohort while national authorities retain supervision of the remainder, a structural bifurcation that active-defence and compliance-technology functions at Lithuania-domiciled firms will need to navigate as a dual-reporting-line reality rather than a simple handover. Whether this domestic and supranational investment translates into resolved MONEYVAL ratings will become visible at the next enhanced follow-up report, expected within 2026, which will test whether the Recommendation 6, 7 and 28 deficiencies, covering targeted financial sanctions and DNFBP supervision, have been addressed by the supervisory tools the FCIS has developed. A sectoral risk methodology built for VASPs does not, on its own, extend to the DNFBP registration gap for accountants and real estate agents identified elsewhere in the evidence for this cycle; closing that separate gap would require either an extension of the FCIS methodology to a currently unregistered population of obliged entities, or a distinct legislative fix delivered through the still-unspecified 6AMLD transposition vehicle. This combination of national technical capacity-building and supranational institutional design is, at this stage, better characterised as promising infrastructure than as a resolved control environment: the enforcement record from the EMI and crypto sector this cycle demonstrates that risk-based supervisory tools existed in principle before the most recent failures were identified, indicating implementation and enforcement follow-through remain the binding constraint rather than tool availability alone. #### Outlook The nearest forward-watch item is the July 2026 public hearing of AMLA on ongoing-monitoring guidelines, which will provide the first concrete signal of how AMLA supervisory expectations will interact with the already-completed sectoral risk methodology of the FCIS. The more consequential horizon item is the entity-selection methodology for the initial cohort of approximately forty entities under AMLA direct supervision, not yet published but expected ahead of the 2028 start date; until it is published, Lithuania-domiciled EMI and VASP firms cannot determine with confidence whether they will fall within the direct-supervision perimeter of AMLA or remain under purely national oversight, a genuine planning uncertainty for compliance-technology investment decisions at the firm level. Cumulative analysis D6 Compliance Technology & Active Defence Cumulative analysis · cross-cycle historical This is the first cumulative synthesis for the compliance technology and active defence domain in Lithuania, integrating the baseline evidence into a single state-of-the-domain reading. The compliance-technology and active-defence posture of Lithuania is, at this baseline, the most structurally clear of the six domains: a completed domestic capacity-building project sits directly ahead of an EU-level supervisory build-out that will eventually reach the same firms. The Financial Crime Investigation Service completed a 2022-2024 EU-funded Technical Support Instrument project that strengthened risk-based AML/CFT supervision domestically, including the development of a VASP sectoral risk methodology, a concrete deliverable directly relevant to the recurring EMI and crypto control failures identified elsewhere in this baseline evidence, since a sectoral risk methodology is precisely the kind of supervisory tool that could, if applied consistently, have identified the risk-assessment and monitoring-scenario deficiencies later found at Pervesk UAB. At the EU level, the Anti-Money Laundering Authority continues its institutional build-out, including a scheduled July 2026 public hearing on ongoing-monitoring guidelines, a near-term signal on supervisory expectations that will directly affect Lithuania-domiciled obliged entities once finalised. This sits ahead of the planned 2028 direct-supervision start of AMLA for approximately 40 high-risk cross-border obliged entities, a cohort assessed as potentially including Lithuania-domiciled EMI and VASP firms given their cross-border footprint. This baseline synthesis treats the domestic supervisory-capacity investment of Lithuania and the EU-level build-out of AMLA as parallel, complementary tracks rather than a single national reform sequence, meaning the compliance-technology posture of Lithuania is currently strengthening on two fronts simultaneously, national and supranational, even though neither track has yet fully closed the control gaps visible in the enforcement record. This dual-track build-out must be read against the standing backdrop of the three-instrument EU AML Package, a durable structural fact rather than a single-cycle development: the directly applicable AML Regulation, Regulation (EU) 2024/1624, effective 10 July 2027, the sixth AML Directive requiring national transposition, with the transposition vehicle and date for Lithuania not yet specified, and the AMLA Regulation, Regulation (EU) 2024/1620, establishing the Authority itself. The supervisory perimeter of AMLA is a hybrid one by design: it will not replace national supervision by the Bank of Lithuania and the Financial Crime Investigation Service wholesale, but will instead directly supervise a defined high-risk cross-border cohort while national authorities retain supervision of the remainder, a structural bifurcation this synthesis will continue to track as it affects Lithuania-domiciled firms directly. Whether this domestic and supranational investment translates into resolved MONEYVAL ratings will become visible at the next enhanced follow-up report, expected within 2026, which will test whether the Recommendation 6, 7 and 28 deficiencies, covering targeted financial sanctions and DNFBP supervision, have been addressed by the supervisory tools the FCIS has developed. This baseline notes explicitly that a sectoral risk methodology built for VASPs does not, on its own, extend to the DNFBP registration gap for accountants and real estate agents identified in the enabler-jurisdiction domain; closing that separate gap would require either an extension of the FCIS methodology to a currently unregistered population of obliged entities, or a distinct legislative fix delivered through the still-unspecified 6AMLD transposition vehicle. This combination of national technical capacity-building and supranational institutional design is, at this baseline stage, better characterised as promising infrastructure than as a resolved control environment: the enforcement record from the EMI and crypto sector this cycle demonstrates that risk-based supervisory tools existed in principle before the most recent failures were identified, indicating implementation and enforcement follow-through remain the binding constraint rather than tool availability alone. Looking forward, the nearest forward-watch item is the July 2026 public hearing of AMLA on ongoing-monitoring guidelines, which will provide the first concrete signal of how AMLA supervisory expectations will interact with the already-completed sectoral risk methodology of the FCIS. The more consequential horizon item is the entity-selection methodology for the initial cohort of approximately forty entities under AMLA direct supervision, not yet published but expected ahead of the 2028 start date; until it is published, Lithuania-domiciled EMI and VASP firms cannot determine with confidence whether they will fall within the direct-supervision perimeter of AMLA or remain under purely national oversight. This synthesis will integrate, rather than append, further developments in AMLA institutional build-out and any confirmed entity-selection methodology in subsequent cycles. Cumulative analysis This is the first cumulative synthesis for the compliance technology and active defence domain in Lithuania, integrating the baseline evidence into a single state-of-the-domain reading. The compliance-technology and active-defence posture of Lithuania is, at this baseline, the most structurally clear of the six domains: a completed domestic capacity-building project sits directly ahead of an EU-level supervisory build-out that will eventually reach the same firms. The Financial Crime Investigation Service completed a 2022-2024 EU-funded Technical Support Instrument project that strengthened risk-based AML/CFT supervision domestically, including the development of a VASP sectoral risk methodology, a concrete deliverable directly relevant to the recurring EMI and crypto control failures identified elsewhere in this baseline evidence, since a sectoral risk methodology is precisely the kind of supervisory tool that could, if applied consistently, have identified the risk-assessment and monitoring-scenario deficiencies later found at Pervesk UAB. At the EU level, the Anti-Money Laundering Authority continues its institutional build-out, including a scheduled July 2026 public hearing on ongoing-monitoring guidelines, a near-term signal on supervisory expectations that will directly affect Lithuania-domiciled obliged entities once finalised. This sits ahead of the planned 2028 direct-supervision start of AMLA for approximately 40 high-risk cross-border obliged entities, a cohort assessed as potentially including Lithuania-domiciled EMI and VASP firms given their cross-border footprint. This baseline synthesis treats the domestic supervisory-capacity investment of Lithuania and the EU-level build-out of AMLA as parallel, complementary tracks rather than a single national reform sequence, meaning the compliance-technology posture of Lithuania is currently strengthening on two fronts simultaneously, national and supranational, even though neither track has yet fully closed the control gaps visible in the enforcement record. This dual-track build-out must be read against the standing backdrop of the three-instrument EU AML Package, a durable structural fact rather than a single-cycle development: the directly applicable AML Regulation, Regulation (EU) 2024/1624, effective 10 July 2027, the sixth AML Directive requiring national transposition, with the transposition vehicle and date for Lithuania not yet specified, and the AMLA Regulation, Regulation (EU) 2024/1620, establishing the Authority itself. The supervisory perimeter of AMLA is a hybrid one by design: it will not replace national supervision by the Bank of Lithuania and the Financial Crime Investigation Service wholesale, but will instead directly supervise a defined high-risk cross-border cohort while national authorities retain supervision of the remainder, a structural bifurcation this synthesis will continue to track as it affects Lithuania-domiciled firms directly. Whether this domestic and supranational investment translates into resolved MONEYVAL ratings will become visible at the next enhanced follow-up report, expected within 2026, which will test whether the Recommendation 6, 7 and 28 deficiencies, covering targeted financial sanctions and DNFBP supervision, have been addressed by the supervisory tools the FCIS has developed. This baseline notes explicitly that a sectoral risk methodology built for VASPs does not, on its own, extend to the DNFBP registration gap for accountants and real estate agents identified in the enabler-jurisdiction domain; closing that separate gap would require either an extension of the FCIS methodology to a currently unregistered population of obliged entities, or a distinct legislative fix delivered through the still-unspecified 6AMLD transposition vehicle. This combination of national technical capacity-building and supranational institutional design is, at this baseline stage, better characterised as promising infrastructure than as a resolved control environment: the enforcement record from the EMI and crypto sector this cycle demonstrates that risk-based supervisory tools existed in principle before the most recent failures were identified, indicating implementation and enforcement follow-through remain the binding constraint rather than tool availability alone. Looking forward, the nearest forward-watch item is the July 2026 public hearing of AMLA on ongoing-monitoring guidelines, which will provide the first concrete signal of how AMLA supervisory expectations will interact with the already-completed sectoral risk methodology of the FCIS. The more consequential horizon item is the entity-selection methodology for the initial cohort of approximately forty entities under AMLA direct supervision, not yet published but expected ahead of the 2028 start date; until it is published, Lithuania-domiciled EMI and VASP firms cannot determine with confidence whether they will fall within the direct-supervision perimeter of AMLA or remain under purely national oversight. This synthesis will integrate, rather than append, further developments in AMLA institutional build-out and any confirmed entity-selection methodology in subsequent cycles. domain_sub_briefs · D6 · Cumulative analysis Periodic updates (2) 11 Sep 2026 · fim-2026-08-21 #### Compliance Technology and Active Defence The Bank of Lithuania's 2026 inspection plan includes, for the first time, standardised AML/CTF inspection templates. This is an incremental but structurally relevant compliance-technology development: standardisation of inspection methodology is a precondition for comparable, auditable supervisory output across obliged entities, and its introduction this cycle is assessed with only moderate confidence given a single T4-tier corroborating account of the inspection plan's contents. The development is best read as a watch-status signal rather than a confirmed structural shift, since the templates' actual content, scope of application across sectors, and enforcement consequences have not yet been independently verified to a primary regulatory source this cycle. #### Outlook Watch for corroboration of the standardised inspection template detail to a primary Bank of Lithuania publication, and for whether the templates are extended to the newly-authorised CASP population as part of the same supervisory-technology push. A future cycle showing the templates applied in a specific inspection outcome would upgrade this from a watch-status compliance-technology signal to a confirmed structural development. #### AML/CTF Regime Two distinct signals define Lithuania's AML/CTF regime this cycle. First, secondary reporting describes a Bank of Lithuania 2026 inspection programme that prioritised AML/CTF supervision, culminating in an August 2026 letter to heads of financial market participants addressing 2025 inspection findings. That letter is reported to have flagged customer due diligence, record-keeping, internal controls, employee training and suspicious transaction reporting as recurring enforcement risks across supervised financial market participants, and the same reporting states that one electronic-money institution was barred from onboarding new customers and serving existing ones while an inspection was still running. FNTT is reported to have recorded more than EUR 6.2 million in fines over the prior year. This body of findings rests on a single Tier-3 commentary synthesis; the underlying FNTT letter itself has not been independently retrieved this cycle, so these figures and characterisations carry probable rather than confirmed confidence. Continue reading Second, and on a firmer evidentiary footing, a FATF/MONEYVAL follow-up report shows Lithuania's Recommendation 2 — covering national cooperation and coordination on AML/CFT/CPF — re-rated from Partially Compliant to Compliant. Lithuania remains in enhanced follow-up under the MONEYVAL process, with no plenary grey-list action taken this cycle. Under the FIM designation set, Lithuania carries no FATF call-for-action or grey-list designation, so neither Countermeasures nor Increased monitoring applies to it. Read together, these two signals present a regime that is simultaneously improving on a specific technical-compliance dimension (Recommendation 2) while continuing to surface recurring operational control deficiencies (CDD, record-keeping, reporting) across supervised entities at the domestic supervisory level. This is consistent with a maturing but not yet fully settled AML/CTF supervisory framework. #### Outlook Publication of the underlying FNTT August 2026 letter, if it becomes independently available, would allow a firmer assessment of the scale and nature of the recurring control deficiencies currently known only through secondary synthesis. Lithuania's continued enhanced follow-up status under MONEYVAL means further Recommendation re-ratings in subsequent follow-up rounds remain the relevant benchmark to watch. Cumulative analysis D7 AML/CTF Regime Cumulative analysis · cross-cycle historical #### AML/CTF Regime Lithuania's AML/CTF regime rests on the Law on the Prevention of Money Laundering and Terrorist Financing, with the Financial Crime Investigation Service (FCIS) functioning as both supervisor and financial intelligence unit. Lithuania remains under MONEYVAL's enhanced follow-up procedure originating from its 2018 mutual evaluation, but this cycle's standing follow-up record shows incremental re-ratings, including a shift of the recommendation on regulation and supervision from partially-compliant to largely-compliant, assessed with high confidence against a Tier-1 assessment-body source. This progress corresponds with Lithuania's implementation of a risk-based AML/CFT supervision reform focused on the FCIS AML-CFT Supervisory Unit. Against this backdrop of incremental technical-compliance improvement, the Bank of Lithuania imposed, on 4 August 2026, a temporary interim restriction on UAB Lux International Payment System, an electronic-money institution licensed since 2021, barring it from serving new and existing customers over suspected serious deficiencies in AML/CFT and other legal requirements. The restriction was authorised by a regional administrative court, indicating that it proceeded through a formal judicial-authorisation step rather than purely administrative fiat. This is assessed with high confidence, though the primary corroborating account is Tier-3 trade press rather than a Tier-1 regulator statement, a sourcing caveat worth carrying forward. Read together, the MONEYVAL re-rating and the EMI restriction present a jurisdiction whose supervisory framework is improving in technical-compliance terms while simultaneously demonstrating active, individually-targeted enforcement capacity, an architecture-over-incident reading that treats the restriction as evidence the improving framework is being operationalised rather than as an isolated incident. #### Outlook Watch for the outcome of the Lux International Payment System restriction, whether it results in remediation, a formal licence action, or an extended restriction period, as the clearest near-term test of enforcement follow-through. Watch also for the AMLA's finalisation, due 10 July 2026, of technical standards on AML/CFT supervisory-college functioning under AMLD6, which Lithuania's FCIS will implement on transposition and which will shape future cross-border supervisory cooperation. Cumulative analysis #### AML/CTF Regime Lithuania's AML/CTF regime rests on the Law on the Prevention of Money Laundering and Terrorist Financing, with the Financial Crime Investigation Service (FCIS) functioning as both supervisor and financial intelligence unit. Lithuania remains under MONEYVAL's enhanced follow-up procedure originating from its 2018 mutual evaluation, but this cycle's standing follow-up record shows incremental re-ratings, including a shift of the recommendation on regulation and supervision from partially-compliant to largely-compliant, assessed with high confidence against a Tier-1 assessment-body source. This progress corresponds with Lithuania's implementation of a risk-based AML/CFT supervision reform focused on the FCIS AML-CFT Supervisory Unit. Against this backdrop of incremental technical-compliance improvement, the Bank of Lithuania imposed, on 4 August 2026, a temporary interim restriction on UAB Lux International Payment System, an electronic-money institution licensed since 2021, barring it from serving new and existing customers over suspected serious deficiencies in AML/CFT and other legal requirements. The restriction was authorised by a regional administrative court, indicating that it proceeded through a formal judicial-authorisation step rather than purely administrative fiat. This is assessed with high confidence, though the primary corroborating account is Tier-3 trade press rather than a Tier-1 regulator statement, a sourcing caveat worth carrying forward. Read together, the MONEYVAL re-rating and the EMI restriction present a jurisdiction whose supervisory framework is improving in technical-compliance terms while simultaneously demonstrating active, individually-targeted enforcement capacity, an architecture-over-incident reading that treats the restriction as evidence the improving framework is being operationalised rather than as an isolated incident. #### Outlook Watch for the outcome of the Lux International Payment System restriction, whether it results in remediation, a formal licence action, or an extended restriction period, as the clearest near-term test of enforcement follow-through. Watch also for the AMLA's finalisation, due 10 July 2026, of technical standards on AML/CFT supervisory-college functioning under AMLD6, which Lithuania's FCIS will implement on transposition and which will shape future cross-border supervisory cooperation. domain_sub_briefs · D7 · Cumulative analysis Standing baseline position Active EMI-sector AML/CFT supervision evidenced by an August 2026 interim restriction on UAB Lux International Payment System, alongside continued MONEYVAL enhanced follow-up with incremental re-ratings. Periodic updates (2) 6 Oct 2026 · fim-2026-10-06 #### AML/CTF Regime Lithuania's AML/CTF regime, built on the Law on the Prevention of Money Laundering and Terrorist Financing (No VIII-275), demonstrates this cycle a structural property that deserves emphasis over any single incident: the enhanced due diligence perimeter under article 14(1)(3) is set not by domestic statute amendment but by dynamic reference to the European Commission's high-risk third-country list. When Commission Delegated Regulations 2026/46 and 2026/83 added Russia to that list, with effect from 29 January 2026, alongside Bolivia and the British Virgin Islands, the Lithuanian EDD obligation toward those jurisdictions arose automatically, without a Seimas vote, a ministerial order, or any other domestic legislative step. This is the architecture-over-incident reading: the Commission's own delegated-regulation process has become, for every EU member state including Lithuania, a more consequential lever over firm-level AML obligations than most domestic legislative calendars, because its effect is instantaneous and uniform across the bloc the moment a new regulation enters into force. The same mechanism had already operated earlier, under Delegated Regulation 2025/1184, which added ten jurisdictions including Algeria, Kenya, Lebanon and Venezuela to the list while removing eight others including Panama, the Philippines and the UAE; each of those additions and removals passed through to Lithuanian EDD obligations on the same automatic basis. A second, independent trigger operates alongside the Commission list. Article 14(1)(4) requires enhanced due diligence toward customers and beneficial owners connected to jurisdictions that the Financial Action Task Force has separately identified as high-risk. Because the Commission list and the FATF findings are not the same instrument and do not necessarily move in lockstep, a jurisdiction can be high-risk for Lithuanian EDD purposes on one basis without being so on the other, or vice versa. Firms relying on a single combined high-risk feed risk missing obligations that arise under only one of the two tracks; the two triggers must be monitored as distinct inputs into the same due-diligence decision. The regime's customer-identification architecture carries its own structural rigidity worth foregrounding for an AML/CTF audience specifically. Article 11(1) does not permit remote identification generally subject to a reasonableness standard; it enumerates five closed routes — third-party reliance under article 13, an EU eID scheme at high or substantial assurance, a qualified electronic signature, live video combined with either an advanced e-signature or a captured face image alongside the original document, or a first payment from a qualifying EU or equivalent account plus a certified paper identity copy. A compliance programme that treats this as a flexible principles-based standard, rather than a closed list against which any onboarding flow must be mapped, is building on a misreading of the statute. The translation underlying this reading carries medium confidence and the precise statutory wording would benefit from local-language confirmation before the mapping exercise is finalised for any specific onboarding product. The low-risk electronic money derogation under articles 9(4) and 9(5) is narrower than some comparator frameworks. It applies to non-reloadable instruments capped at EUR 150 in stored value, restricted to goods-and-services use, with no anonymous funding and no cash redemption, and separately permits account opening on limited data with full identification completed within a month, subject to ongoing monitoring. Lithuania does not carry the EUR 50 remote-payment-instrument limb seen elsewhere, meaning firms calibrating a pan-EU low-risk e-money product cannot assume Lithuanian law mirrors the broadest version of the simplified due diligence permitted under comparable regimes. Record retention closes the structural picture for this cycle: registration logs, identity document copies, beneficial-owner data and related account documentation must be kept for eight years from the end of the relationship under articles 19(10) and 19(11), a period at the longer end of what comparator EU jurisdictions require, with shorter five-year periods for some correspondence. For firms operating retention schedules across multiple EU markets, Lithuania's eight-year floor is the binding constraint wherever a shorter harmonised schedule would otherwise apply. What remains unresolved, and should be read as a gap rather than a finding, is Lithuania's transposition status for the sixth Anti-Money Laundering Directive and its alignment timeline with the directly-applicable AML Regulation and the build-out of the Anti-Money Laundering Authority's supervisory perimeter. The present research cycle did not establish a transposition date, and the AML Law No VIII-275 continues to operate as the live national instrument in the interim. #### Outlook The automatic-incorporation mechanism under article 14(1)(3) means that the single most consequential near-term variable for Lithuania's AML/CTF perimeter is not domestic legislative activity but the Commission's own delegated-regulation cadence: any further addition to, or removal from, the EU high-risk third-country list will change Lithuanian firm-level EDD obligations the moment it enters into force, with no intervening domestic process. Firms with Lithuanian exposure should treat the Commission list, rather than the Seimas calendar, as the primary forward-looking signal to monitor for this regime, while separately tracking FATF findings as an independent second trigger. The 6AMLD transposition timeline remains an open question to be resolved in a future cycle once further research establishes Lithuania's position relative to the AMLR/AMLA build-out. Baseline-Tracked Domains with No Current-Cycle Escalation (1 of 8) - D8 Commercial Activity: Standing coverage — no activity this cycle. Regulatory horizon Consultation 2027 · ±year ### AMLA direct-supervision eligibility data collection (PIs/EMIs) EBA's draft reporting framework will determine, via a 31 December 2026 reference date, which PIs and EMIs face direct AMLA supervision rather than purely national supervision. source not collected 1 dated · 4 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### EU Council designated 743 individuals and 826 entities on 12 October 2026, binding directly on Lithuanian obliged entities. The expanded list requires screening updates across correspondent banking and trade finance customer typologies without a domestic transposition step, since EU Council decisions take direct effect in Lithuania. 2 evidence refs Compliance ### MONEYVAL launched its sixth-round evaluation of Lithuania on 13-14 October 2026, running to a reported May 2028. The evaluation window overlaps with the EU AML Regulation reaching full application on 10 July 2027, meaning Lithuania's assessed framework and the bloc's harmonised regime will be developing concurrently. 1 evidence refs Legal ### No Lithuania-specific Tier-1 implementing instrument for the 12 October sanctions package was independently retrieved this pass. The binding effect of the EU designation is not in question given direct applicability, but the domestic evidentiary record for this package currently rests on secondary commentary rather than a primary Lithuanian source. 2 evidence refs Board ### Lithuania's AML/CFT framework enters a multi-year evaluation cycle against the backdrop of an expanding EU sanctions list. The convergence of the MONEYVAL evaluation and the EU AML Regulation's 2027 application date represents a sustained period of regulatory scrutiny for Lithuania's financial sector architecture. 1 evidence refs CTO ### Lithuania's authorised crypto-asset service provider population held steady at four plus two notifications. No new authorisation or crypto-sanctions-evasion finding was located this cycle, indicating stability rather than expansion in the Bank of Lithuania's supervised population under the current transitional framework. 1 evidence refs Risk ### The sanctions list population Lithuanian entities must screen against expanded and extended simultaneously this cycle. The new October designations combined with the extension of over 3,000 existing listings to 2029 increase the standing screening population without any near-term expiry relief. 2 evidence refs Operations ### Screening lists require updating for 743 newly designated individuals and 826 entities effective from the 12 October 2026 package. Transaction monitoring and screening systems covering correspondent banking and trade finance exposure should reflect the expanded list, which took direct effect without domestic transposition. 1 evidence refs Audit ### No material change for this persona this cycle. No material change for this persona this cycle Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture stable EU Council's 12 Oct 2026 package is the largest single EU listing expansion since 2022; no LT-specific evasion-architecture finding beyond bloc-level application. T2 · EU AML Package / AMLA no_change No new AMLR/6AMLD/AMLA transposition movement for LT located this cycle; full application remains dated 10 July 2027. T3 · FATF Grey List no_change Lithuania is not FATF grey-listed; no plenary movement located this cycle. T4 · Beneficial-Ownership Register Status no_change No LT-specific BO-registry development located this cycle. T5 · Crypto & Digital-Asset Integrity stable Bank of Lithuania's MiCA CASP regime continues to operate with a small authorised population (4 CASPs plus 2 Art.60(4) notifiers). T6 · Sanctions Regime Divergence no_change No new EU/US/UK autonomous-listing divergence specific to LT located this cycle. Registers ### Enforcement actions - 10 Apr 2025 - 29 Aug 2025 - 12 Jun 2025 - 22 Jul 2026 - 1 Jun 2026 - 9 Feb 2026 - 14 Apr 2026 - 9 Apr 2026 - 4 Aug 2026 - 2026-04 - 2026 - 2026-09 - 6 Mar 2026 - Joint raid on a company allegedly exporting EU-manufactured, sanctioned goods to Russia and Belarus by rerouting them through Central Asian countries to defeat EU export restrictions. 10 Apr 2025 - Fine and formal warning for failing to properly assess risk from high-risk clients and foreign financial institutions, not adapting monitoring scenarios to ML typologies, and insufficient staff AML training. 29 Aug 2025 - Lithuanian customs disclosed rejecting 28,854 export requests for goods bound for Russia and Belarus that attempted to exploit a 'medical exemption' classification to bypass EU sanctions. 12 Jun 2025 ### Sanctions changes - 23 Oct 2025 - 15 Dec 2025 - 24 Feb 2025 - 18 Jul 2025 - 14 Oct 2026 - 12 Oct 2026 - EU's 19th sanctions package against Russia targeted Russian energy, third-country banks facilitating circumvention, and crypto-asset providers, extending the transaction ban to third-country financial and crypto operators connected to Russia's financial messaging system. 23 Oct 2025 - The EU Council broadened the Belarus sanctions regime to cover hybrid activities against EU member states -- disinformation/FIMI, critical-infrastructure disruption, migrant instrumentalisation and unauthorised entry -- a decision explicitly following meteorological-balloon airspace incursions into Lithuania. 15 Dec 2025 - EU adopted its 16th sanctions package against Russia (three-year invasion anniversary), mirroring trade sanctions in the parallel Belarus regime and adding restrictions on services, software, deposits, crypto-asset wallets and transport; the Belarus sanctions regime was concurrently prolonged to 28 February 2026. 24 Feb 2025 - EU's 18th sanctions package upgraded the existing SWIFT ban on Belarusian banks (in view of Belarus' complicity in Russia's war) to a full transaction ban, and extended equivalent full transaction bans on other listed Russian/Belarusian banks. 18 Jul 2025 ### Regulatory horizon (register) - UK ECCTA 2023 failure-to-prevent-fraud offence - standing watch - AMLA technical standards on AML/CFT supervisory colleges - AMLA technical standards on AML/CFT supervisory colleges - AMLA direct-supervision eligibility data collection (PIs/EMIs) - MONEYVAL 6th round mutual evaluation of Lithuania - AML Regulation (AMLR) becomes directly applicable EU-wide - AMLA begins direct supervision of ~40 high-risk entities - 6AMLD transposition deadline for Lithuania - Next MONEYVAL follow-up report on Lithuania's R.6/7/28 gaps ### Active schemes - Belarus/Russia sanctioned-goods transit and exemption abuse - Lithuania-licensed crypto firms servicing sanctioned Russian clients - Non-public UBO register shielding ownership links - Licensed EMI/bank layering for offshore proceeds (legacy and current) Sources - [https://reforms-investments.ec.europa.eu/technical-support-instrument-0/financial-sector-and-access-finance/strengthening-risk-based-amlcft-supervision-lithuania_en](https://reforms-investments.ec.europa.eu/technical-support-instrument-0/financial-sector-and-access-finance/strengthening-risk-based-amlcft-supervision-lithuania_en) - [https://www.lb.lt/en/news/targetgroup.Electronic+money+institutions+](https://www.lb.lt/en/news/targetgroup.Electronic+money+institutions+) - [https://www.fatf-gafi.org/en/publications/Mutualevaluations/Lithuania-MONEYVAL-FUR-2024.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Lithuania-MONEYVAL-FUR-2024.html) - [https://fincrimecentral.com/bank-of-lithuania-blocks-lux-international-psp/](https://fincrimecentral.com/bank-of-lithuania-blocks-lux-international-psp/) - [https://www.nortonrosefulbright.com/en/knowledge/publications/644c5392/the-new-eu-amlcft-regime-has-arrived-are-you-ready](https://www.nortonrosefulbright.com/en/knowledge/publications/644c5392/the-new-eu-amlcft-regime-has-arrived-are-you-ready) - [https://key2law.com/en/news/amlkyc-obligations-for-crypto-businesses-in-lithuania](https://key2law.com/en/news/amlkyc-obligations-for-crypto-businesses-in-lithuania) - [Ecovis Lithuania](https://ecovis.lt/regrally-insights-aml-ctf-regulation-september-2026/) - [Ecovis Lithuania](https://ecovis.lt/regrally-insights-payment-services-regulation-september-2026/) - [ACAMS](https://www.acams.org/en/enforcement-action/bank-lithuania-fines-walletto-uab-eu290000-amlctf-failures) - [Wikimedia Foundation](https://en.wikipedia.org/wiki/European_Merchant_Bank) - [Open Government Partnership](https://www.opengovpartnership.org/members/lithuania/commitments/LT0030/) - [https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [https://eur-lex.europa.eu/eli/reg_del/2025/1184/oj/eng](https://eur-lex.europa.eu/eli/reg_del/2025/1184/oj/eng) - [https://e-seimas.lrs.lt/rs/actualedition/TAIS.41300/DmYPaFHxKG/format/ISO_PDF/](https://e-seimas.lrs.lt/rs/actualedition/TAIS.41300/DmYPaFHxKG/format/ISO_PDF/) - [https://ekspertai.eu/straipsnis/lietuvos-bankas-paaiskino-kodel-vien-seb-veiklos-rusijoje-nepakanka-poveikio-priemonems-li](https://ekspertai.eu/straipsnis/lietuvos-bankas-paaiskino-kodel-vien-seb-veiklos-rusijoje-nepakanka-poveikio-priemonems-li) - [https://rm.coe.int/moneyval-2023-22-li-5thround-4thenhfur/1680aec731](https://rm.coe.int/moneyval-2023-22-li-5thround-4thenhfur/1680aec731) - [https://ecovis.lt/regrally-insights-aml-ctf-regulation-september-2026/](https://ecovis.lt/regrally-insights-aml-ctf-regulation-september-2026/) - [https://sumsub.com/blog/aml-regulations-in-lithuania/](https://sumsub.com/blog/aml-regulations-in-lithuania/) - [https://www.lrt.lt/en/news-in-english/19/3082338/lithuania-imposes-national-asset-freezes-on-russian-businessmen-usmanov-and-fridman](https://www.lrt.lt/en/news-in-english/19/3082338/lithuania-imposes-national-asset-freezes-on-russian-businessmen-usmanov-and-fridman) - [https://hromadske.ua/en/europa/272522-lithuania-freezes-assets-of-russian-billionaires-fridman-and-usmanov-after-eu-lifts-sanctions](https://hromadske.ua/en/europa/272522-lithuania-freezes-assets-of-russian-billionaires-fridman-and-usmanov-after-eu-lifts-sanctions) - [https://mezha.net/eng/bukvy/8502d23b_lithuania_fines_individuals/](https://mezha.net/eng/bukvy/8502d23b_lithuania_fines_individuals/) - [https://www.lb.lt/en/news/paytend-europe-uab-has-lost-its-licence](https://www.lb.lt/en/news/paytend-europe-uab-has-lost-its-licence) - [https://www.lb.lt/en/news/an-authorisation-of-a-crypto-asset-service-provider-granted-to-micar-assets-uab](https://www.lb.lt/en/news/an-authorisation-of-a-crypto-asset-service-provider-granted-to-micar-assets-uab) - [https://ecovis.lt/regrally-insights-aml-ctf-regulation-august-2026/](https://ecovis.lt/regrally-insights-aml-ctf-regulation-august-2026/) - [https://www.legalnodes.com/article/lithuania-crypto-license](https://www.legalnodes.com/article/lithuania-crypto-license) - [https://www.coe.int/en/web/moneyval/-/moneyval-launches-the-evaluation-process-of-the-republic-of-lithuania](https://www.coe.int/en/web/moneyval/-/moneyval-launches-the-evaluation-process-of-the-republic-of-lithuania) - [https://www.sanctionsexpert.com/post/last-week-s-major-developments-in-sanctions-october-12-to-october-16-2026](https://www.sanctionsexpert.com/post/last-week-s-major-developments-in-sanctions-october-12-to-october-16-2026) - [https://ecovis.lt/regrally-insights-sanctions-regulation-october-2026/](https://ecovis.lt/regrally-insights-sanctions-regulation-october-2026/) - [https://www.urm.lt/en/sanctions](https://www.urm.lt/en/sanctions) - [Lithuania](https://www.fatf-gafi.org/en/countries/detail/Lithuania.html) - [Mutual Evaluation of Lithuania](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationoflithuania.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Europe](https://www.fatf-gafi.org/en/countries/continents/europe.html) - [Committee of Experts on the Evaluation of Anti-Money Laundering Measures (MONEYVAL)](https://www.fatf-gafi.org/en/countries/global-network/committee-of-experts-on-the-evaluation-of-anti-money-laundering-.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/publications/Mutualevaluations.html) - [Lithuania's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Lithuania-MONEYVAL-FUR-2024.html) - [News](https://www.fatf-gafi.org/en/the-fatf/news.html) - [Lithuania's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/mer-lithuania-2018.html) - [1 Anti-money laundering and counter-terrorist financing measures Lithuania](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Lithuania-MONEYVAL-FUR-2024.pdf.coredownload.inline.pdf) - [Lithuania crypto country guide | Elliptic](https://www.elliptic.co/country-guides/lithuania) - [Moneyval 1st Follow-Up-Report Lithuania](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Moneyval-1st-Follow-Up-Report-Lithuania.pdf.coredownload.inline.pdf) - [Financial Crime Investigation Service, Ministry of the Interior (AFCOS) - European Anti-Fraud Office](https://anti-fraud.ec.europa.eu/organisations/financial-crime-investigation-service-ministry-interior-afcos_en) - [Moneyval-Mutual-Evaluation-Report-Lithuania-2018. ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Moneyval-Mutual-Evaluation-Report-Lithuania-2018.pdf.coredownload.inline.pdf) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [Lithuania](https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/workinggroup2/2018-June-6-7/Contributions_NV/Lithuania_EN.pdf) - [Follow-up report to Lithuania's assessment of anti-money laundering and counter-terrorist financing measures](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-lithuania-2020.html) - [Lithuania Fines Bankera-Affiliated Firm Over Compliance Failures | OCCRP](https://www.occrp.org/en/news/lithuania-fines-bankera-affiliated-firm-over-compliance-failures) - [Lithuania's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-lithuania-2018.html) - [Special Measures | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/special-measures) - [Strengthening Risk-Based AML/CFT Supervision in Lithuania - Reforms and Investments](https://reforms-investments.ec.europa.eu/technical-support-instrument-0/financial-sector-and-access-finance/strengthening-risk-based-amlcft-supervision-lithuania_en) - [OLAF intelligence supports Lithuanian Customs in major sanctions evasion probe - European Commission](https://anti-fraud.ec.europa.eu/media-corner/news/olaf-intelligence-supports-lithuanian-customs-major-sanctions-evasion-probe-2025-04-24_en) - [Russia Uses Medical Exemption to Evade Sanctions, Lithuania Says - Bloomberg](https://www.bloomberg.com/news/articles/2025-06-12/russia-uses-medical-exemption-to-evade-sanctions-lithuania-says) - [EU sanctions against Russia: questions and answers - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-russia-explained/) - [EU sanctions against Belarus - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-belarus/) - [Belarusian Opposition Demands Action after OCCRP Uncovers Multi-billion Scheme | OCCRP](https://www.occrp.org/en/news/belarusian-opposition-demands-action-after-occrp-uncovers-multi-billion-scheme) - [Belarus: Council broadens scope of sanctions regime to cover hybrid activities against EU member states - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/12/15/belarus-council-broadens-scope-of-sanctions-regime-to-cover-hybrid-activities-against-eu-member-states/) - [After Revealed Violations, Lithuania Toughens Sanctions Implementation | OCCRP](https://www.occrp.org/en/news/after-revealed-violations-lithuania-toughens-sanctions-implementation) - [EU Accused of Trying to Defuse Kaliningrad Standoff With Eased Rules - Bloomberg](https://www.bloomberg.com/news/articles/2022-06-27/eu-may-be-trying-to-defuse-kaliningrad-standoff-with-eased-rules) - [Timeline - EU sanctions against Belarus - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-belarus/timeline-eu-sanctions-against-belarus/) - [Transport of goods in transit through the Union between the Kaliningrad Oblast and Russia - Finance](https://finance.ec.europa.eu/publications/transport-goods-transit-through-union-between-kaliningrad-oblast-and-russia_en) - [Transactive Systems Loses Bank of Lithuania License Over Compliance Failings - Bloomberg](https://www.bloomberg.com/news/articles/2023-06-01/uk-payments-firm-transactive-stripped-of-lithuanian-license) - [Virtual Asset Service Provider (VASP): Definition, Compliance & Examples](https://www.trmlabs.com/glossary/virtual-asset-service-provider-vasp) - [Fatf-gafi](https://fatf-gafi.org/media/fatf/documents/reports/fur/Moneyval-1st-Follow-Up-Report-Lithuania.pdf) - [Lithuania Imposes Record Fine on Crypto Company Over Sanctions - Bloomberg](https://www.bloomberg.com/news/articles/2024-07-10/lithuania-imposes-record-fine-on-crypto-company-over-sanctions) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [Virtual Assets](https://www.fatf-gafi.org/en/topics/virtual-assets.html) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Virtual Assets: Targeted Update on Implementation of the FATF Standards on VAs and VASPs](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/targeted-update-virtual-assets-vasps-2024.html) - [Anti-money laundering and countering the financing of terrorism at EU level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-eu-level_en) - [Homepage - Authority for Anti-Money Laundering and Countering the Financing of Terrorism](https://finance.ec.europa.eu/financial-crime/amla_en) - [FAQs - Authority for Anti-Money Laundering and Countering the Financing of Terrorism](https://finance.ec.europa.eu/financial-crime/amla/frequently-asked-questions_en) - [Timeline: EU action against money laundering and terrorist financing - Consilium](https://www.consilium.europa.eu/en/policies/fight-against-terrorist-financing/timeline/) - [Anti-money laundering directive V (AMLD V) - transposition status | European Commission](https://ec.europa.eu/info/publications/anti-money-laundering-directive-5-transposition-status_en) - [Anti-money laundering and countering the financing of terrorism legislative package - Finance](https://finance.ec.europa.eu/publications/anti-money-laundering-and-countering-financing-terrorism-legislative-package_en) - [Anti-money laundering: Council adopts package of rules - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2024/05/30/anti-money-laundering-council-adopts-package-of-rules/) - [About AMLA - Authority for Anti-Money Laundering and Countering the Financing of Terrorism](https://finance.ec.europa.eu/financial-crime/amla/about-amla_en) - [How Europe’s Retreat From Corporate Transparency is Shielding the Corrupt | OCCRP](https://www.occrp.org/en/feature/how-europes-retreat-from-corporate-transparency-is-shielding-the-corrupt) - [European e-Justice Portal - Beneficial Ownership Registers – search for beneficial ownership information](https://webgate.ec.europa.eu/e-justice/38576/EN/beneficial_ownership_registers__search_for_beneficial_ownership_information) - [FAQ: The EU Ruling on Ownership Transparency and What It Means for Journalists | OCCRP](https://www.occrp.org/en/project/beneficial-ownership-data-is-critical-in-the-fight-against-corruption/faq-the-eu-ruling-on-ownership-transparency-and-what-it-means-for-journalists) - [Patchy Progress in Setting Up Public Beneficial Ownership Registers in the EU | Global Witness](https://www.globalwitness.org/en/campaigns/corruption-and-money-laundering/anonymous-company-owners/5amld-patchy-progress/) - [Beneficial Ownership Registers Interconnection System](https://webgate.ec.europa.eu/e-justice/searchBoris.do) - [AVAILABILITY OF COMPANY BENEFICIAL OWNERSHIP ...](https://www.globalwitness.org/documents/19879/EU_BO_registers_Annex.pdf) - [European e-Justice Portal - Beneficial ownership registers interconnection system (BORIS)](https://webgate.ec.europa.eu/e-justice/38590/EN/beneficial_ownership_registers_interconnection_system_boris?init=true&idSubpage=1) - [Patchy progress in beneficial ownership registers in the EU | Global Witness](https://globalwitness.org/en/campaigns/corruption-and-money-laundering/patchy-progress-in-setting-up-beneficial-ownership-registers-in-the-eu/) - [TI Report: EU Beneficial Ownership Registers Limited and Restricted | OCCRP](https://occrp.org/en/daily/14497-ti-report-eu-beneficial-ownership-registers-limited-and-restricted) - [Guidance on Beneficial Ownership of Legal Persons](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html) - [Huge Ecosystem of Unregulated Payment Providers Helps Scammers Collect Victims’ Money | OCCRP](https://www.occrp.org/en/project/scam-empire/huge-ecosystem-of-unregulated-payment-providers-helps-scammers-collect-victims-money) - [Paysera | EU Digital Finance Platform - European Union](https://digital-finance-platform.ec.europa.eu/observatory/eu-fintech-map/paysera) - [The Troika Laundromat’s Friendly EU Banker | OCCRP](https://www.occrp.org/en/troikalaundromat/the-troika-laundromats-friendly-eu-banker) - [Multi-National Money Laundering Network Dismantled in Lithuania | OCCRP](https://occrp.org/en/daily/18514-multi-national-money-laundering-network-dismantled-in-lithuania) - [EU’s Fintech Hub Tightens Supervision After Massive Expansion - Bloomberg](https://www.bloomberg.com/news/articles/2023-02-10/eu-s-fintech-hub-tightens-supervision-after-massive-expansion) - [The bank of Lithuania starts adding fintech companies' innovations on the blockchain | Shaping Europe’s digital future](https://digital-strategy.ec.europa.eu/en/news/bank-lithuania-starts-adding-fintech-companies-innovations-blockchain) - [Lithuania Revokes License of UAB Payrnet for Violating Money Laundering Laws - Bloomberg](https://www.bloomberg.com/news/articles/2023-06-22/payments-firm-that-moved-8-3-billion-last-year-loses-license) - [Multi-National Money Laundering Network Dismantled in Lithuania | OCCRP](https://www.occrp.org/en/daily/18514-multi-national-money-laundering-network-dismantled-in-lithuania) - [Operation BELENOS II: Over €2.7 Million Seized During Customs Operation Targeting Illicit Financial Flows - European Anti-Fraud Office](https://anti-fraud.ec.europa.eu/media-corner/news/operation-belenos-ii-over-eu27-million-seized-during-customs-operation-targeting-illicit-financial-2024-12-20_en) - [Europol Dismantles Criminal Network Laundering Millions | OCCRP](https://www.occrp.org/en/news/europol-dismantles-criminal-network-laundering-millions) - [Latvia and Lithuania Detain 108 in Multi-Million Euro Call Center Scam | OCCRP](https://www.occrp.org/en/news/latvia-and-lithuania-detain-108-in-multi-million-euro-call-center-scam) - [Europol: Money Laundering at the Heart of a Multi-Billion EU Criminal Economy | OCCRP](https://www.occrp.org/en/news/europol-money-laundering-at-the-heart-of-a-multi-billion-eu-criminal-economy) - [Europol: Money Laundering at the Heart of a Multi-Billion EU Criminal Economy](https://www.occrp.org/en/27-ccwatch/cc-watch-briefs/18027-europol-money-laundering-at-the-heart-of-a-multi-billion-eu-criminal-economy) - [Europol: EU Crime Networks Regenerate Fast | OCCRP](https://www.occrp.org/en/news/europol-eu-crime-networks-regenerate-fast) - [Police Across Europe Crush Ponzi Schemes, Recover Lost Money | OCCRP](https://www.occrp.org/en/news/police-across-europe-crush-ponzi-schemes-recover-lost-money) - [Money-laundering criminals are adapting to new technology faster than authorities can keep up, EU report says - ICIJ](https://www.icij.org/investigations/fincen-files/money-laundering-criminals-are-adapting-to-new-technology-faster-than-authorities-can-keep-up-eu-report-says/) - [OFAC Targets DPRK IT Workers Using Crypto](https://www.chainalysis.com/blog/ofac-targets-north-korean-it-workers-crypto-march-2026/) - [North Korea IT Workers: Inside the DPRK’s Crypto Laundering Network](https://www.chainalysis.com/blog/dprk-it-workers-north-korea-crypto-laundering-networks/) - [Beyond IT Worker Fraud: OFAC's Latest DPRK Designations Show Broader Sanctions and National Security Risk | TRM Blog](https://www.trmlabs.com/resources/blog/beyond-it-worker-fraud-ofacs-latest-dprk-designations-show-broader-sanctions-and-national-security-risk) - [OFAC lists 53 crypto addresses of sanctioned North Korean Cheil Credit Bank](https://www.elliptic.co/blog/ofac-lists-53-crypto-addresses-of-sanctioned-north-korean-cheil-credit-bank) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [OFAC sanctions a fraud network for assisting the North Korean (DPRK) regime](https://www.elliptic.co/blog/ofac-sanctions-a-fraud-network-for-assisting-the-north-korean-dprk-regime) - [OFAC Sanctions Tracker: How Sanctions Impact Crypto Crime - Chainalysis](https://www.chainalysis.com/blog/ofac-sanctions/) - [Crypto Sanctions: 2026 Crypto Crime Report](https://www.chainalysis.com/blog/crypto-sanctions-2026/) - [Crypto Regulatory Affairs: OFAC sanctions North Korea’s crypto laundering networks](https://www.elliptic.co/blog/analysis/crypto-regulatory-affairs-ofac-sanctions-north-korea-s-crypto-laundering-networks) - [Cyber-related Designation Removal; North Korea Designation Update and Removal | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250321) - [FATF / MONEYVAL](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Moneyval-Mutual-Evaluation-Report-Lithuania-2018.pdf.coredownload.inline.pdf) - [FATF / MONEYVAL](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Lithuania-MONEYVAL-FUR-2024.html) - [Council of the European Union (Consilium)](https://www.consilium.europa.eu/en/press/press-releases/2025/12/15/belarus-council-broadens-scope-of-sanctions-regime-to-cover-hybrid-activities-against-eu-member-states/) - [European Anti-Fraud Office (OLAF)](https://anti-fraud.ec.europa.eu/media-corner/news/olaf-intelligence-supports-lithuanian-customs-major-sanctions-evasion-probe-2025-04-24_en) - [European Commission (DG REFORM / Council of Europe project)](https://reforms-investments.ec.europa.eu/technical-support-instrument-0/financial-sector-and-access-finance/strengthening-risk-based-amlcft-supervision-lithuania_en) - [OCCRP](https://www.occrp.org/en/news/lithuania-fines-bankera-affiliated-firm-over-compliance-failures) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-06-12/russia-uses-medical-exemption-to-evade-sanctions-lithuania-says) - [OCCRP](https://www.occrp.org/en/feature/how-europes-retreat-from-corporate-transparency-is-shielding-the-corrupt) - [Bloomberg](https://www.bloomberg.com/news/articles/2024-07-10/lithuania-imposes-record-fine-on-crypto-company-over-sanctions) - [OCCRP](https://www.occrp.org/en/troikalaundromat/the-troika-laundromats-friendly-eu-banker) - [European Commission / AMLA](https://finance.ec.europa.eu/financial-crime/amla/frequently-asked-questions_en) - [Elliptic](https://www.elliptic.co/country-guides/lithuania) Coverage gaps fim-int-2026-07-07-G001: Lithuania's specific 6AMLD transpos… fim-int-2026-07-07-G001: Lithuania's specific 6AMLD transposition vehicle and confirmed transposition date have not yet been published or collected this cycle. [resolved] fim-int-2026-07-07-G002: Independent, non-OCCRP corroboratio… fim-int-2026-07-07-G002: Independent, non-OCCRP corroboration of the Pervesk UAB/Bankera enforcement narrative and its current remediation status has not been obtained this cycle. [resolved] fim-int-2026-07-07-G003: Current STR-filing volume data for … fim-int-2026-07-07-G003: Current STR-filing volume data for Lithuanian notaries, company-service providers, MVTS providers, and real estate agents has not been collected, limiting quantification of the DNFBP reporting gap. [resolved] fim-int-2026-07-07-G004: The exact completion date of the 20… fim-int-2026-07-07-G004: The exact completion date of the 2024 Europol/Eurojust dismantling of the Italy-linked EUR2 billion laundering network routed through a Lithuania-registered institution has not been independently confirmed. [resolved] fim-int-2026-07-07-G005: The ratified typology library (sent… fim-int-2026-07-07-G005: The ratified typology library (sentinel-typology-library-v1.0.json) was not supplied as context this cycle, preventing typology-indicator matching against Lithuania's developments. [resolved] fim-int-2026-08-05-G001: Lithuania's Member-State-specific 6… fim-int-2026-08-05-G001: Lithuania's Member-State-specific 6AMLD transposition instrument and date have not been independently confirmed this cycle. [resolved] fim-int-2026-08-05-G002: Conflict-finance corridor detail fo… fim-int-2026-08-05-G002: Conflict-finance corridor detail for Lithuania beyond the 2025 Kaunas dual-use case was not independently re-verified this cycle. [resolved] fim-int-2026-08-05-G003: Lithuania's current FATF mutual-eva… fim-int-2026-08-05-G003: Lithuania's current FATF mutual-evaluation status has no direct T1 FATF source confirming no-change this cycle. [resolved] fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): D2 beneficial-ownership register effectiveness was not actively re-verified against the AMLR interconnection timeline this cycle. [resolved] fim-int-2026-08-21-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): D3 enabler-jurisdiction and D4 conflict-finance material for LT yielded no findings and were logged as coverage gaps rather than earned nulls. [resolved] fim-int-2026-08-21-G003: Tier D watch jurisdictions (KH, LA,… fim-int-2026-08-21-G003: Tier D watch jurisdictions (KH, LA, MX, CO) were not actively queried this cycle due to pooled union budget constraints. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No T1 Bank of Lithuania supervisory-letter document was directly retrieved this cycle; findings rest on secondary compliance-consultancy reporting. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): No LT-specific conflict-finance (D4) signal was found this cycle. [resolved] fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): The exact MiCA VASP-to-CASP transitional backstop date for Lithuania (national vs EU Art 143(3)) could not be reconciled from available sources this cycle. [resolved] fim-int-2026-09-28-G004: Tier-D jurisdiction watch (KH, LA, … fim-int-2026-09-28-G004: Tier-D jurisdiction watch (KH, LA, MX, CO) and the Yemen/Houthi CTF channel check were not actively resourced within this cycle's pooled search budget for LT. [resolved] fim-int-2026-10-06-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-06-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): Lithuanian AML Law art. 13 (third-party reliance) full text and quoted verbatim substantiation not retrieved; precise conditions on 'sufficient means' and the high-risk-third-country exclusion require a verbatim source quote to upgrade confidence. [resolved] fim-int-2026-10-06-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-06-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): Lithuanian text translation of the five AML Law art. 11(1) remote-identification routes should be confirmed locally; the English summary relied on an unverified translation. [resolved] fim-int-2026-10-06-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-06-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): Lithuania's 6AMLD (Directive (EU) 2024/...) transposition status and timeline relative to the AMLR/AMLA build-out was not established in this cycle's research; the jurisdiction risk tracker therefore carries no transposition date. [resolved] fim-int-2026-10-12-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-12-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No Bank of Lithuania primary press release on the SEB Art 73 matter was independently located; sourcing is press-reported only. [resolved] fim-int-2026-10-12-G002: Tier D jurisdiction watch (Cambodia… fim-int-2026-10-12-G002: Tier D jurisdiction watch (Cambodia, Laos, Mexico, Colombia) was not separately swept in this LT-bound pass; coverage sits with the monitor's global cycle. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No T1 Lithuanian government gazette text was retrieved this cycle for the Usmanov/Fridman national sanctions decision; confidence capped by secondary T2 corroboration only. [open] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): LT-specific AMLR/6AMLD transposition status not established this cycle; no primary source retrieved. [open] fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', 'value': 'D2'}): D2 (beneficial ownership), D3 beyond the Paytend action, D4 (conflict finance) and D6 (compliance technology) had thin or no coverage for LT this cycle due to shared search-budget allocation across five union consumers. [open] fim-int-2026-11-01-G001: No LT-specific Tier-1 implementing … fim-int-2026-11-01-G001: No LT-specific Tier-1 implementing instrument for the EU Council's 12 Oct 2026 sanctions package was independently retrieved this pass. [open] fim-int-2026-11-01-G002: No LT-specific finding for D2 (Bene… fim-int-2026-11-01-G002: No LT-specific finding for D2 (Beneficial Ownership), D3 (Enabler Jurisdictions), D4 (Conflict Finance), D6 (Compliance Technology) or D8 (Commercial Activity) within the strict 2026-10-18 to 2026-11-01 window. [open] FIM-GAP-001 (D2): Lithuania's beneficial ownership registry … FIM-GAP-001 (D2): Lithuania's beneficial ownership registry is not publicly accessible; access is restricted to parties demonstrating 'legitimate interest,' a standard that remains ill-defined since the 2022 CJEU Sovim/W.M. ruling invalidated mandatory EU-wide public access. FIM-GAP-002 (D1): FATF Recommendations 6 (TF targeted financ… FIM-GAP-002 (D1): FATF Recommendations 6 (TF targeted financial sanctions), 7 (PF targeted financial sanctions) and 28 (DNFBP regulation/supervision) remain rated Partially Compliant in Lithuania's December 2024 MONEYVAL follow-up report, reflecting unclear freezing/de-listing procedures and incomplete DNFBP oversight. FIM-GAP-003 (D3): No registration framework exists for accou… FIM-GAP-003 (D3): No registration framework exists for accountants and real estate agents as DNFBPs, and MVTS providers, real estate agents, notaries and CSPs have historically filed few or no suspicious transaction reports despite facing material ML/TF risk exposure. FIM-GAP-004 (D5): Recurring AML/CFT control failures across … FIM-GAP-004 (D5): Recurring AML/CFT control failures across Lithuania's licensed EMI and crypto-asset sector (Pervesk/Bankera, Payeer, Transactive Systems, Payrnet) indicate persistent supervisory capacity strain relative to the scale and speed of fintech-sector growth, despite an EU-funded 2022-2024 project to strengthen FCIS risk-based supervision. ## Evidence #### Confidence-tiered claims A Russia-licensed subsidiary of a supervised bank's parent group is not, by itself, grounds for Banking Law Art 73 supervisory measures against the LT-incorporated entity. [[Source 1]](#sec-sources) Probable · 1 source In MONEYVAL enhanced follow-up process following December 2018 5th-round MER, most recently re-rated in the 4th Enhanced FUR adopted 15 December 2023. [[Source 1]](#sec-sources) Probable · 1 source Temporarily prohibited the electronic money institution Lux International Payment System from providing financial services to new and existing customers while an inspection is ongoing. [[Source 1]](#sec-sources) Probable · 1 source The Bank of Lithuania licenses and supervises financial market participants, including for AML/CTF purposes. [[Source 1]](#sec-sources) Probable · 1 source Lithuania is bound by the EU AML Regulation directly (amlr_direct) as an EEA member; AMLR directly applicable from 10 July 2027. [[Source 1]](#sec-sources) Probable · 1 source Alisher Usmanov and Mikhail Fridman, running to end-2027 [[Source 1]](#sec-sources) Probable · 1 source systemic AML/CFT monitoring and internal-control failures, including failure to file STRs with FNTT [[Source 1]](#sec-sources) Probable · 1 source CDD, record-keeping, internal controls, employee training and suspicious transaction reporting across supervised financial market participants [[Source 1]](#sec-sources) Probable · 1 source Bank of Lithuania, the fourth such LT authorisation [[Source 1]](#sec-sources) Probable · 1 source Compliant (from Partially Compliant) [[Source 1]](#sec-sources) Probable · 1 source MONEYVAL's 6th-round mutual evaluation of Lithuania formally launched 13-14 Oct 2026 in Vilnius, running to a reported May 2028. [[Source 1]](#sec-sources) Probable · 1 source EU Council's 12 Oct 2026 package designated 743 individuals and 826 entities over Russia's military-industrial supply chain; directly applicable in Lithuania as an EU member state. [[Source 1]](#sec-sources) Probable · 1 source Over 3,000 existing Russia-related individual listings extended to 22 September 2029. [[Source 1]](#sec-sources) Probable · 1 source URM prepares and submits EU sanctions proposals and transposes EU autonomous Russia-regime measures into national implementation. [[Source 1]](#sec-sources) Probable · 1 source Lithuania holds 4 CASP authorisations plus 2 Art.60(4) notifications per ESMA's 30 Sep 2026 interim register; no new LT CASP authorisation dated within this cycle's window. [[Source 1]](#sec-sources) Probable · 1 source