Requirements

Basic license requirements for establishing EMI in Lithuania:

  • A minimum capital requirement of €350,000 to establish an electronic money institution (e-money) license in Lithuania.
  • To safeguard client funds either with a segregated client bank account or with an insurance policy.
  • It is advised (but not required by law) that the Lithuanian EMI has one director / representative in Lithuania who can represent the company to the Lithuanian regulator.
  • The heads of an electronic money institution shall be:
  1. the head of administration.
  2. the board members (management board) - at least 3 members.
  3. the supervisory board members (supervisory board) - at least 3 members.
  4. the persons responsible for the management of the electronic money issuance business (heads of structural subdivisions).
  5. persons responsible for the provision of payment services, where an electronic money institution provides payment services not related to electronic money issuance.
  • The heads of an EMI must be of good repute and possess the qualification and experience necessary to properly perform their duties.
  • At least two members of the Management Board shall have a higher education diploma in the area of Law, Management, Business Administration or Economics or at least 1 year of working experience in the mentioned areas over the period of 5 previous years.
  • Head of the EMI shall have a higher education diploma in the area of Law, Management, Business Administration or Economics and at least 2 years of working experience in the position of the Head of a legal entity or head of its structural unit over the period of 8 previous years.

Required documents and data for establishing EMI in Lithuania:

  1. Basic company details.
  2. KYC documents.
  3. Proof of origin and receipt of finances.
  4. Evidence of initial capital.
  5. Programme of operations.
  6. Business plan.
  7. Structural organisation.
  8. Description of measures for safeguarding client funds.
  9. Description of internal control mechanisms including governance and business continuity arrangements.
  10. Description of procedure for monitoring, handling and following up on security incidents and security-related customer complaints.
  11. Description of process for filing, monitoring, tracking and restricting access to sensitive payment data.
  12. Description of the principles and definitions applicable to the collection of statistical data on performance, transactions and fraud.
  13. Description of internal control mechanisms to comply with anti money laundering and counter terrorist financing requirements (AML/CFT obligations).
  14. Questionnaires of the shareholders, the management and key function holders.
  15. Professional indemnity insurance.
  16. Details of auditors.
  • Additional documents may be requested by the Regulator at its discretion. 

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