CRYPTO LICENSE
IN LITHUANIA
CASP authorization in Lithuania under EU MiCA for crypto companies
AMS assists crypto businesses in obtaining CASP authorization in Lithuania under MiCA, translating EU legal requirements into a practical licensing plan aligned with the expectations of the Lithuanian supervisory authority.
We don’t just «file paperwork.»
AMS builds a full-fledged operational and compliance system that the regulator expects to see in a real CASP: governance and accountability, AML/CFT controls, ICT security and resilience, regular reporting, and real «substance» in the EU.
Also we work with exchanges, custodians and wallet providers, brokers, trading platforms, market makers, OTC desks, and other crypto service models that need stable, fully regulated access to the European market.
WHY LITHUANIA IS AN EXCELLENT CHOICE FOR MiCA LICENSING
Lithuania has significant experience in fintech within the EU and remains a practical choice for companies transitioning to MiCA requirements. A mature supervisory environment, developed compliance infrastructure, and familiarity with regulated financial models make it a reliable option for CASP authorization.
Regulator and complexity of fintech models
Lithuania gained early experience in supervising fintech and crypto-related entities. In practice, this often translates into clearer expectations, more structured review procedures, and fewer “conceptual gaps” when assessing non-standard operating models.
Trust and reputation
In the crypto sector, a jurisdiction’s reputation influences onboarding and partnerships. Lithuania is perceived as a reliable environment with EU regulation, which simplifies interaction with liquidity providers, technology vendors, and institutional or corporate clients.
Banking and payments
For many CASPs, accessing banking services is more difficult than obtaining a license. Lithuania offers a developed ecosystem of EMIs, payment institutions, and banks that are accustomed to onboarding regulated businesses operating within MiCA-oriented AML systems. This can improve account opening results, reduce risks, and support stable payment operations.
MiCA passporting across the EEA
CASP, authorized in Lithuania, can use MiCA passporting to expand across the European Economic Area (EEA). In practical terms, this means that you can notify regulators and provide approved services in other EU/EEA countries without having to go through the full licensing process again in each jurisdiction, provided that you do not go beyond the approved perimeter.
AMS CRYPTO LICENSING — PACKAGES & IMPLEMENTATION MODELS
AMS supports the process of obtaining a MiCA license in Lithuania at all stages: we determine the scope of licensing, build an operational structure, prepare documents in the format expected by the regulator, conduct dialogue during the review process, and maintain compliance after approval.
New CASP Company
For businesses establishing a new MiCA-regulated company in Lithuania.
Includes:
- Assessment of your business concept and financial model for compliance with MiCA and the Lithuanian supervisory approach
- Selection of relevant CASP service categories and determination of the scope of authorization
- Registration of a Lithuanian company and setup of basic governance (roles, responsibilities, oversight)
- Capital planning and organizational structuring under MiCA prudential requirements
- Design and implementation of an operational AML/CFT system (procedures, controls, escalation logic)
- Preparation of a complete set of documents for CASP authorization
- Coordination during the supervisory review and Q&A cycles (clarifications, updates, and follow-up actions)
- Structured compliance support after authorization
READY-MADE CASP COMPANY
For clients who intend to purchase an already authorized CASP company in Lithuania with a valid license.
Includes:
- Selection and full support in the purchase of an existing licensed CASP company.
- Registration of the transfer of shares and mandatory corporate changes.
- Bringing the business model into line with the current scope of the license.
- Updating/refreshing management and AML/compliance policies and controls where necessary.
- Preparation and submission of mandatory notifications and reports to the regulator.
- Post-transaction compliance support.
ADDITIONAL SUPPORT FOR CRYPTO COMPANIES IN LITHUANIA
Licensing is just one component of sustainable operations in the EU. We also provide operational and compliance services that directly impact supervisory trust, banking onboarding, and long-term MiCA compliance.
Crypto accounting and financial reporting
Accounting support for crypto businesses: transaction reconciliation, tax reporting, and preparation of financial statements in accordance with Lithuanian and European standards.
AML & compliance services
End-to-end AML/CFT implementation: system development, internal controls, monitoring logic, regulatory reporting processes, and ongoing compliance with MiCA and Lithuanian AML requirements.
Key roles and local director recruitment
Assistance in recruiting and appointing critical functions: local directors, AML Officer/MLRO, CFO, CTO, Risk, CISO — with a focus on regulatory compliance and operational continuity.
Bank onboarding and relationship support
We prepare your company for successful onboarding with a bank/EMI: we compile a compliance package, develop a compelling description of the operating model, and configure AML/KYC controls to match the verification criteria of financial partners.
Office and local presence
We help you establish a real “presence” in the EU: we determine the format of your presence, set up an office, and configure processes so that it is clear where and by whom decisions are made and how operations are carried out.
HOW AMS GETS RESULTS IN LICENSING
Supervised stress testing
We draft documents so that they correspond to the actual work of the business. Policies and procedures should respond to detailed questions from the regulator, rather than formal compliance with requirements.
Practical licensing methodology
We use applied experience and proven patterns from several jurisdictions, adapting them to your model and review practices in Lithuania.
Readiness to work with banks
AMS builds AML controls, reporting, and risk allocation not only for MiCA, but also to meet the expectations of banks, EMIs, and counterparties.
Management and control functions
We help implement real compliance/AML/MLRO capabilities and support the appointment of directors, CFOs, CTOs, risk managers, and CISOs—avoiding nominal “paper” structures.
Unified interaction model
Legal structuring, MiCA licensing, AML implementation, and operational readiness are conducted as a unified system, resulting in fewer conflicts and “connections” between advisors.
Default post-licensing support
After authorization, we remain involved: regular compliance routines, support for interaction with supervisory authorities, and updates as MiCA practices evolve.
CASP LICENSING IN LITHUANIA — STEP-BY-STEP PROCESS
The process is conducted primarily remotely and follows a consistent logic: confirmation of the scope of work, organization of local presence (if necessary), preparation of documents, supervisory review, and further compliance after approval.
Due diligence & scope confirmation
Estimated timeframe: up to 3 weeks
We map your activities with MiCA service categories and determine the appropriate scope of the license, while identifying potential gaps at an early stage.
Includes:
- Analysis of services, customer scenarios, operating model, and financial plan
- Verification of ownership/UBO transparency and governance readiness
- Gap analysis on AML, ICT, governance, and controls relative to MiCA expectations
- Confirmation of CASP categories and regulatory scope
Assistance with company registration in Lithuania (if necessary)
Estimated timeframe: ~1–2 weeks
If you need to be present in Lithuania, we can help with registration and corporate governance setup.
Includes:
- Registration of a Lithuanian company (if necessary)
- Preparation and submission of corporate documents
- Coordination of registrations and key appointments
Preparation of MiCA documentation package
Estimated timeframe: 1–3 months
AMS develops a complete “supervision-ready” package tailored to your model and risk profile — for real-world scenarios, not just for formal compliance.
Includes:
- Implemented AML/CFT policies, procedures, and internal controls
- Operational model for corporate governance, compliance, and risk management
- Customer protection, complaint handling, and conflict of interest policies
- Documents on ICT controls and operational resilience (MiCA-compliant; taking DORA into account where relevant)
- Financial projections, assumptions, and stress scenarios
- Distribution of responsibilities between management, compliance, and the MLRO function
Submission & supervisory review
Estimated timeframe: 3–12 months
After submission, the regulator reviews the application and sends requests for additional information. We coordinate communication and ensure that responses are consistent, clear, and well-reasoned.
Includes:
- Submission of the CASP authorization package
- Maintaining dialogue with the regulator during the review process
- Processing requests for clarifications and document updates
Post-authorisation compliance support
Once you have obtained your license, we assist you in complying with MiCA requirements in your day-to-day operations and ensure that you are always prepared for supervisory inspections.
Includes:
- Ongoing compliance support and assistance with supervisory interactions
- AML supervision routines and regulatory reporting processes
- Operational and accounting advice as needed
CORE REQUIREMENTS FOR CASP AUTHORISATION IN LITHUANIA
MiCA authorization is granted to companies that can demonstrate genuine readiness: sufficient capital, effective management, implemented AML controls, a secure and reliable IT environment, and credible EU substance. Supervision in Lithuania usually focuses on “operational reality” — whether the business is capable of operating under constant supervision.
Capital & prudential resilience
Capital & prudential resilience
CASP must have own funds commensurate with their services, scale, and risk profile. Under MiCA, prudential requirements are generally calculated as the greater of: a minimum capital threshold or one quarter of fixed operating expenses.
Indicative minimum capital levels:
- Class 1 — from €50,000: non-custodial services (without storage/control of client assets).
- Class 2 — from €125,000: custodial and exchange-related activities.
- Class 3 — from €150,000: trading platforms and services with a higher level of risk.
Additional requirements for certain token issuers (where relevant):
- Asset-backed tokens (ART): €350,000 or 2% of reserve assets.
- Electronic money tokens (EMT): 2–20% of the issued value (depending on the level of risk).
Implemented AML controls and robust IT infrastructure
Implemented AML controls and robust IT infrastructure
Prior to receiving authorization, the AML/CFT system must be effectively implemented and operational, supported by secure IT systems and robust control mechanisms.
The regulator assesses effectiveness (monitoring, escalations, MLRO powers, audit trails, reporting capabilities), not just the existence of written policies.
IT and operational resilience must also reflect DORA principles: continuity, controlled access, incident handling, and resilience of critical functions and data.
Typical supervisory expectations:
- A risk-based onboarding process and full cycle of follow-up checks.
- Transaction monitoring (automated and manual), backed by secure IT system architecture.
- Clear escalation routes and real decision-making authority for the MLRO.
- Data protection, secure record storage, audit logs, and regulatory reporting capability.
- IT risk management, access control, incident response, and resilience measures in line with DORA logic.
Management and key functions
Management and key functions
The applicant must demonstrate a level of corporate governance comparable to that of regulated financial institutions, with a clear distribution of responsibilities across the following areas:
- Compliance and AML
- Risk management
- Information security (CISO or equivalent)
- Operations
- Finance (CFO or equivalent)
- Technology oversight (CTO or equivalent)
Independence and formalization should be commensurate with the complexity of the business and the level of risk.
Requirements for directors
Requirements for directors
Directors are assessed on:
- Relevant experience and competence
- Integrity and compliance with regulatory requirements
- Ability to ensure continuous MiCA compliance
- Availability to interact effectively with supervisors
At least one director must be an EU citizen, reside in the EU, and be able to represent the company on supervisory matters on an ongoing basis.
Presence and operational capability in the EU
Presence and operational capability in the EU
To obtain authorization, a company must meet supervisory expectations regarding the organization of its activities in the EU.
This means:
- Making key management decisions within the EU.
- Being constantly available to interact with the regulator.
- Having sufficient resources, including employees and/or outsourced functions, under the company’s effective control.
A formal presence without actual management and operational activities is not accepted by the regulator.
Transparency of ownership structure
Transparency of ownership structure
Qualifying shareholders are subject to supervisory review. The ownership structure must be:
- Fully transparent and documented.
- Supported by verifiable source of funds and source of wealth
- Economically sound and consistent with the principles of prudent management.
The regulator verifies the traceability of the ownership structure, as well as the risks associated with the integrity and business reputation of shareholders.
WHY THE REVIEW OF CASP APPLICATIONS MAY BE DELAYED
Significant delays are more often caused not by «missing documents». They occur when the supervisory authority concludes that the structure will not be able to operate under MiCA in practice.
Stop doubting. It’s time to get licensed.
If your CASP application is delayed, raises questions, or is already facing resistance from regulators, AMS can help you rebuild your model to meet MiCA expectations, close gaps, and move forward with a «regulator-ready» strategy.
FAQ
Why can CASP applications take months to process?
The regulator identifies structural gaps—unclear licensing scope, weak corporate governance, insufficiently implemented AML controls, unrealistic financial assumptions, or insufficient organizational readiness. This leads to repeated rounds of requests and clarifications.
Why is the review period 3 months in some cases and 12+ months in others?
It depends on the readiness at the time of submission: the complexity of services (custodial services, trading), capital readiness, clarity of the operating model, and the number of issues found during the assessment.
Is it possible to prepare and submit documents without traveling to Lithuania?
Often, yes. However, organizational readiness must be convincing: supervision and control functions in the EU, accessibility for the regulator, and real operational control.
What does “local presence” mean in practice?
Not a decorative office. The regulator expects effective organization of activities in the EU: key decision-making, responsible corporate governance, and accessible compliance functions. A “light” model is possible; a nominal one is almost never possible.
Is there a “light” tax or regulatory regime for CASPs in Lithuania?
No. Standard Lithuanian corporate tax rules apply. Efficiency is achieved through proper structuring and a credible substance model — not a “special crypto tax status.”
Who reviews CASP applications in Lithuania?
Applications are reviewed by the Bank of Lithuania (Lietuvos bankas) as the national competent authority for MiCA. The assessment is conducted for compliance with MiCA requirements, Lithuanian AML legislation, and supervisory practices, with an emphasis on the company’s operational capability.
Does Lithuanian authorization grant the right to expand throughout the EU?
Yes. Under MiCA, an authorized Lithuanian CASP can “passport” approved services throughout the EU/EEA within the approved perimeter.
Is it risky to request multiple services in a single authorization?
Perhaps—if the structure is unable to handle the complexity. A multi-service perimeter is possible, but each activity must be justified, properly capitalized, and backed up by sufficient controls.
What if compliance deteriorates after approval?
MiCA supervision continues after licensing. If capital, AML controls, governance, or interaction with the regulator deteriorate, the authority may impose restrictions, suspend operations, or revoke authorization.