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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.

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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.

01

Company registration

Can be done remotely

02

Opening a capital account

Opening an account for paying in share capital

03

Increasing share capital

Increasing share capital to the required amount

04

Business assessment

Assessing your business and experience against MiCA, gap analysis, preparing a plan for submission to the Bank of Lithuania

05

Document preparation

Gathering and preparing the business plan, policies, key staff and office

06

Application submission

Electronic submission of the CASP licence application to the Bank of Lithuania, completeness check

07

Application review

The Bank of Lithuania assesses documents and requests additional information if needed

08

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

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Experience with major crypto exchanges

Practical experience providing legal support to major EU crypto exchanges in Lithuania since 2021

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Expert approach

Our team consists of practicing lawyers, allowing us to handle legal matters of any complexity in depth

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Trusted by partners

For more than five years we have cooperated with major crypto-licensing service providers in Lithuania, supporting clients worldwide

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Professional qualification

Our lawyers regularly undergo specialised training and hold competencies in AML and crypto-asset regulation

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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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