Compliance Services for Fintech Companies in Lithuania

AML/KYC Framework Design and Implementation
The foundation of every fintech compliance programme is the AML/KYC framework — the set of policies, procedures, and controls that determine how the company identifies, assesses, and manages money laundering and terrorist financing risk. We design and implement AML/KYC frameworks that are tailored to the specific business model, customer base, and risk profile of each fintech client — not adapted from a generic template. The framework is built to satisfy the Bank of Lithuania’s licence application requirements and to withstand supervisory examination after the licence is granted.

• Business-wide ML/TF risk assessment — identifying and scoring the specific risks of the company’s activities, geographies, and customer types
• AML/CFT Compliance Programme — the master policy document defining the company’s full anti-money laundering framework
• Customer Acceptance Policy — defining risk appetite, prohibited categories, and the basis for customer acceptance or rejection decisions
• Customer risk scoring methodology — a documented, consistent approach to classifying customers from low to high ML/TF risk
• Standard CDD procedures — step-by-step onboarding workflows for individual and corporate clients
• Simplified CDD procedures — for low-risk customer categories where simplified measures apply under Lithuanian law
• Enhanced Due Diligence (EDD) procedures — for PEPs, high-risk jurisdictions, complex structures, and other elevated-risk scenarios
• Ongoing monitoring procedures — periodic review of existing client relationships and trigger-based re-KYC

MLRO Function — Outsourced and Advisory
The Money Laundering Reporting Officer (MLRO) is the individual legally responsible for receiving internal suspicious activity reports, deciding whether to file Suspicious Transaction Reports (STRs) with the FNTT, and acting as the primary point of contact for AML supervisory matters. The MLRO must be adequately qualified, given sufficient authority, and protected from interference in the performance of their duties. We provide the MLRO function in two forms: fully outsourced — where we act as the named MLRO — and advisory — where we support an in-house MLRO with specialist guidance.

• Outsourced MLRO — named individual designated as the company’s MLRO for Bank of Lithuania purposes
• Internal SAR assessment — reviewing internal suspicious activity reports and making the filing decision
• STR preparation and submission to the FNTT — within the statutory timeframe
• FNTT liaison — responding to FNTT enquiries, information requests, and freeze orders
• MLRO reporting to the board — regular compliance reports on SAR volumes, STR filings, and AML risk trends
• Advisory MLRO support — supporting an in-house MLRO with specialist guidance on complex cases and regulatory interpretations
• MLRO transition management — where a company is transitioning between MLROs and needs continuity coverage

Transaction Monitoring Framework
Transaction monitoring is the operational core of an AML compliance programme — the continuous process of reviewing customer transactions to identify patterns that may indicate money laundering, terrorist financing, or sanctions evasion. An effective transaction monitoring framework requires documented typologies, calibrated alert thresholds, a defined investigation workflow, and a clear escalation path to the MLRO. We design, implement, and review transaction monitoring frameworks for fintech companies across payment, crypto, and lending sectors.

• Transaction monitoring typologies — documented patterns and red flags specific to the company’s business model
• Alert threshold calibration — setting thresholds that generate actionable alerts without creating alert fatigue
• Alert investigation procedures — step-by-step workflow for handling, investigating, and closing or escalating alerts
• Escalation to MLRO — documented escalation path for alerts that cannot be resolved at the analyst level
• System selection advisory — assessing automated transaction monitoring tools appropriate for the company’s volume and budget
• Model validation — periodic review of the transaction monitoring model to confirm it remains effective as the business evolves
• Typology update service — annual review and update of typologies to reflect current FNTT and EBA guidance

Sanctions Screening
Sanctions compliance is separate from AML compliance — but equally mandatory for Lithuanian fintech companies. Every obliged entity must screen clients and transactions against applicable sanctions lists before onboarding and on an ongoing basis. Lithuanian financial institutions must comply with the sanctions regimes legally applicable to their activities, including EU restrictive measures and relevant UN Security Council sanctions implemented through the applicable legal framework. US OFAC sanctions may also be relevant where the institution, its transactions or counterparties have a sufficient US jurisdictional connection, including certain US-dollar clearing arrangements. However, the use of US dollars does not automatically make every OFAC restriction directly applicable to every Lithuanian transaction. The Financial Crime Investigation Service (FNTT) performs functions related to sanctions implementation and supervision within its statutory competence, but its published information should not be described as a separate universal domestic sanctions list equivalent to the EU and UN sanctions regimes. Violations of EU restrictive measures may result in administrative or criminal liability in Lithuania, depending on the nature of the infringement, the applicable legislation and the circumstances of the case. Criminal liability is not automatically established for every inadvertent sanctions violation. The relevant provisions concerning fault, seriousness of the conduct and statutory exceptions must be assessed individually. Financial institutions must maintain effective sanctions screening, escalation, asset freezing and reporting procedures to prevent and address potential infringements. We design and implement sanctions screening frameworks and provide ongoing screening compliance support.

• Sanctions screening policy — defining the lists screened, the screening frequency, and the hit resolution procedure
• Onboarding screening procedures — name screening at client onboarding against all applicable sanctions lists
• Ongoing screening procedures — periodic re-screening of the existing client base when sanctions lists are updated
• Transaction screening procedures — real-time or batch transaction screening for sanctioned counterparties
• False positive management — documented procedure for assessing and resolving screening hits that are not true matches
• Escalation and freeze procedures — what to do when a true sanctions match is identified; FNTT notification requirements
• Sanctions screening tool selection — advisory on commercially available screening tools appropriate to the company’s scale
• Sanctions compliance training — staff training on EU sanctions obligations and the practical screening workflow

Compliance Testing and Gap Analysis
A compliance framework that exists on paper but is not followed in practice does not satisfy the Bank of Lithuania. The gap between documented procedures and actual operations is the most common finding in AML supervisory examinations. Compliance testing — structured, periodic assessment of whether documented controls are being applied consistently — is the mechanism for identifying and closing that gap before the regulator does. We conduct compliance testing for fintech companies as a standalone engagement and as part of ongoing compliance programme management.

• AML programme gap analysis — comprehensive review of the existing compliance framework against current Bank of Lithuania expectations
• CDD file quality review — sampling and scoring of client onboarding files against the documented CDD procedures
• Transaction monitoring effectiveness testing — reviewing alert data to assess whether the monitoring model is performing as intended
• MLRO function assessment — reviewing the quality and timeliness of SAR assessments and STR decisions
• Staff AML knowledge testing — assessing whether relevant staff have adequate AML knowledge through structured testing
• Remediation planning — prioritised action plan addressing the gaps identified in the testing exercise
• Pre-examination readiness assessment — structured review of all compliance elements ahead of a scheduled Bank of Lithuania examination

Bank of Lithuania Examination Preparation
A Bank of Lithuania AML supervisory examination is a significant event for any licensed fintech entity. Examiners review written policies, sample client files, examine transaction monitoring records, and interview the MLRO and compliance officer. The outcome — satisfactory, with recommendations, or with formal findings — affects the company’s regulatory standing and can result in conditions, fines, or in serious cases, licence suspension. We prepare companies for supervisory examinations by reviewing the complete compliance framework, identifying and remediating gaps, and coaching key personnel on what to expect.

• Pre-examination compliance review — full assessment of the compliance programme against known Bank of Lithuania examination criteria
• Document organisation and preparation — structuring the compliance documentation for examiner review
• CDD file remediation — identifying and addressing deficiencies in client onboarding files before examiners review them
• Transaction monitoring record review — ensuring alert investigation records are complete and defensible
• MLRO preparation — coaching the MLRO and compliance officer on examination interviews and question handling
• Mock examination — simulated examination exercise to identify remaining gaps under examination conditions
• Post-examination response support — drafting responses to examination findings and preparing remediation plans