MiCA Crypto Licensing in Lithuania
Obtaining a MiCA Crypto Licence in Lithuania
MiCA (Markets in Crypto-Assets Regulation EU 2023/1114) is a single EU regulatory regime for crypto-assets. A CASP licence allows you to provide the full range of crypto services across the EU.
After submitting documents, the Bank of Lithuania responds within 5 days on compliance with requirements, and decides on the licence within 3 months.
Why Lithuania
Why choose Lithuania to obtain a MiCA licence?
Access to the entire EU market and scaling
- Once licensed in Lithuania, you can operate in all EU countries without additional permits
Fast process
- Response on compliance within 5 days, licensing decision within 3 months
Low costs
- Lithuania is one of the most affordable EU jurisdictions with low operating costs
Strong fintech hub
- The Bank of Lithuania has issued over 250 payment institution licences; there are already cases of major players obtaining MiCA licences
Access to the banking system
- Possibility to open an account with a Lithuanian bank for share capital and client funds
Flexibility for international teams
- Possibility of remote work
What MiCA enables
A CASP licence grants the status of Crypto-Asset Service Provider and allows: operating and providing services remotely across the EU; custody of crypto-assets; operating a trading platform for crypto-assets; crypto-fiat and crypto-crypto exchange; execution of client orders; placing of tokens; reception and transmission of orders; advice on crypto-assets; portfolio management of crypto-assets; transfer of crypto-assets on behalf of clients.
Additionally: a simplified dual CASP and PSP licence for transferring and holding stablecoin EMTs; issuing stablecoins (ART, EMT), utility tokens and publishing a Whitepaper; working with funds and large investors; crypto-as-a-service and white-label exchanges.
Requirements
Key requirements for obtaining a MiCA licence in Lithuania
EUR 125,000. The company must pay for shares in cash into a bank account with a Lithuanian credit institution.
Shareholders and at least 3 board members may be non-residents. The director must be an EU resident; the Bank of Lithuania recommends that the director and one board member be Lithuanian residents.
Office in Lithuania, presence of partners and clients in Lithuania.
Employed staff who are Lithuanian residents.
One board member is responsible for implementing AML procedures.
AML/CFT, risk management, ICT and business continuity (under DORA), client asset custody, complaint handling, conflicts of interest.
Programme of operations, a 3-year business plan with financial projections, EU market integration, including a link to Lithuania.
An account with an EU bank for holding client funds.
Whitepaper, reserves for ART/EMT, prior approval.
Process
CASP licensing procedure
The process may take 3-6 months. A preliminary meeting with the Bank of Lithuania is recommended, as is a UBO check request to the Security Commission before submitting documents.
Company registration
Can be done remotely
Opening a capital account
Opening an account for paying in share capital
Increasing share capital
Increasing share capital to the required amount
Business assessment
Assessing your business and experience against MiCA, gap analysis, preparing a plan for submission to the Bank of Lithuania
Document preparation
Gathering and preparing the business plan, policies, key staff and office
Application submission
Electronic submission of the CASP licence application to the Bank of Lithuania, completeness check
Application review
The Bank of Lithuania assesses documents and requests additional information if needed
Decision and launch
Licence issued upon approval by the Bank of Lithuania
Dual licence
Simplified dual CASP and PSP licence for stablecoin EMTs
Why it is needed
Required for holding, administering and transferring EMTs on behalf of clients
Alternative
A CASP may obtain a PsP licence, find a partner holding one, or exclude EMT-related services
Strategic advantage
Opens an opportunity the Bank of Lithuania would normally be reluctant to approve
Review timeline
Shorter than for a standard PsP licence and reviewed in parallel with the CASP licence
Capital
Minimum share capital is EUR 125,000, which also covers the CASP licence requirements
Documents
Application, programme of operations, business plan, capital calculation tables and separate financial projections for EMT transaction volumes
Support
What our CASP licensing support includes
UBO check
Checking the UBO and source of income confirming share capital, request to the Security Commission
Incorporation
Increasing share capital and opening accounts for capital and client funds
Gap analysis
Analysing gaps in the company's procedures and developing a plan to address them under MiCA
Business plan & ICT
Reviewing the business plan, programme of operations and ICT documentation
Policies
Preparing AML/CFT, risk management and other procedural policies
Governance structure
Assistance setting up the company's management structure
Documentation & reporting
Developing effective record-keeping and reporting systems
Staffing
Assistance finding and hiring qualified staff, an internal auditor and an accountant
Application filing
Filing the application with the Bank of Lithuania and support throughout the review
Operational Support
Ongoing Support for Licensed Crypto Companies During Operations
MiCA, PSD2 & AML
Consulting on the implementation of MiCA, PSD2 and AML legislation.
Legal Opinions
Preparation of legal opinions on various legal matters.
Bank Accounts
Opening operational bank accounts with Lithuanian and other EU banks and payment systems that work with cryptocurrency.
AML Audits
Conducting AML audits of internal procedures and policies, and supporting companies during regulator inspections.
Legal Consulting
Legal consultations on Lithuanian legislation.
Accounting Services
Providing accounting services, along with regular and ongoing accounting consultations.
GDPR Documentation
Preparation of GDPR documents and documentation on data protection and client information matters.
Court Representation
Providing an attorney for communication with law enforcement authorities and representation in court in the event of disputes or conflict situations.
Regulator Communication
Support during communication with the regulator.
Our advantages
Experience with major crypto exchanges
Practical experience providing legal support to major EU crypto exchanges in Lithuania since 2021
Expert approach
Our team consists of practicing lawyers, allowing us to handle legal matters of any complexity in depth
Trusted by partners
For more than five years we have cooperated with major crypto-licensing service providers in Lithuania, supporting clients worldwide
Professional qualification
Our lawyers regularly undergo specialised training and hold competencies in AML and crypto-asset regulation
Among the first on the market
We were among the first legal teams to support crypto-licensing in Lithuania
Contact us
Ready to start the CASP licensing process under MiCA?
Our team of lawyers experienced in crypto regulation will simplify the process for you. If we see you have no chance of obtaining a MiCA licence in Lithuania, we will tell you right away and offer alternative solutions. Let us handle the details so you can focus on growing your crypto business in the EU!
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