Cryptocurrency Licence in Lithuania

Lithuania is one of the few member states of the European Union in which legal financial transactions with cryptocurrency are possible, and there is an official permit for the conduct and regulation of cryptocurrency business by the state (FCIS). Widely recognized in the traditional financial sector (FIAT) and in e-money licensing, the Lithuanian government also offers transparent and cost-effective virtual currency authorization.

Lithuania offers a friendly and regulated legal environment for companies offering cryptocurrency exchange services and cryptocurrency wallet services, with clear and transparent regulations in force since 2020.

In Lithuania, it is possible to obtain two types of licenses for working with virtual currency:

Cryptocurrency exchange license (Cryptocurrency exchange license). A company with such a license is able to exchange digital currency for FIAT or vice versa, or cryptocurrency for another cryptocurrency, receiving a commission for the services provided.

Crypto wallet and custodian services license (Crypto wallet and custodian services license). A company with such a license may operate a customer wallet to store cryptocurrency, including generating and storing encrypted client keys.

Both licenses granted are controlled by the Lithuanian Financial Crime Investigation Service (FCIS)

COST OF CRYPTOCURRENCY LICENSE

PACKAGE «COMPANY & CRYPTO LICENSE IN LITHUANIA»

9,900 EUR
PACKAGE «COMPANY & CRYPTO-LICENSE IN LITHUANIA» INCLUDES:
  • Establishment or purchase of a ready-made company
  • Deposit of share capital (EUR 2,500)
  • Preparation of legal company documents
  • Assistance in director employment/KYC/AML officer and information State Social Insurance Fund
  • Lease of legal address at Vilnius Business Centre for 1 year
  • Review of the business model and the structure of the Cryptocurrency Company
  • Assistance in opening a bank account for cryptocurrency companies
  • Procedural Rules and KYC/AML Company Procedures
  • Preparation of notifications, forms and supporting documents for submission to FCIS and Business Regests of Lithuania
  • Paying company registration government fees
  • Paying government crypto license fees
  • General counselling (5 hours)

*establishment of the company and receipt of the cryptocurrency license is possible to implement completely remotely, without visiting Lithuania.

Requirements for the applicant company

In order to prevent the legalization of the proceeds of crime, the activities of cryptocurrency companies are monitored by the relevant legal institutions. Board member as well as owners of the company must meet the requirements of impeccable reputation and have no criminal record.

Companies providing services in the cryptocurrency sector are subject to the following requirements:

  • At least one owner (natural or legal person)
  • One board member (may also be the owner)
  • AML Compliance Officer (may be the same as board member)
  • Company virtual address in Lithuania
  • All clients must undergo a background check and identification procedure
  • Customer data must be kept with the possibility of submitting them to the regulator
  • The company must have internal control and risk assessment procedures
  • Reporting to the regulator (Financial Crimes Investigation Service)

There is no need for owners or board member of a cryptocurrency company to be physically present in Lithuania so that foreigners/non-residents of Lithuania can legally engage in crypto related activities while in their country.

General provisions

During the licensing process, the regulator has the right to request additional information and a detailed/white paper description of the proposed activity of the cryptocurrency company. A licence may be issued only after all necessary information is considered sufficient and all licensing conditions are met.

Any change in the structure of the cryptocurrency company after the receipt of the license (address, owner, board member, beneficiary, AML officer) requires the registration of changes in the registry with the provision of a complete set of documents.

The application for a cryptocurrency licence is considered by the Bank of Lithuania, regulated by the FCIS and issued by the Business Register. FCIS is an independent structural unit of the Lithuanian Police and Border Police Department.

Cryptocurrency companies are regulated by the Law on the Prevention of Money Laundering and Financing of Terrorism, in particular Order No V-5 of January 2020.

The cryptocurrency company has no special reporting requirements to the tax authorities. Accounting must be provided in the same way as for any other Lithuanian company. FCIS can always make prescriptions and queries about the activities of a cryptocurrency company. The basic requirement of the FCIS is to comply with AML/KYC requirements, such as the collection of client data from a crypto related project and the possibility of making them available to the regulator on demand.

Licensing process

In order to apply for a cryptocurrency license, a limited liability company (UAB) must be established in Lithuania to provide cryptocurrency exchange or storage services. The minimum requirement for the company’s authorized capital is 2,500 EUR. The establishment of a cryptocurrency company can be carried out upon a visit to Vilnius or completely remotely by proxy without the need to visit Lithuania.

Today UAB is one of the most frequently used and popular forms of business activity in Lithuania.

Uždaroji akcinė bendrovė (UAB) in translation from the Lithuanian language means Closed Joint-Stock Company. The statutory capital of the UAB is divided into shares which can be sold in whole or in part, donated or hereditary. UAB must have at least one owner (natural or legal person) and one director (natural person) authorized to sign on behalf of the company.

Stages of obtaining a cryptocurrency licence in Lithuania:

  1. Signing of cooperation agreement with Company in Lithuania UAB
  2. Preparation of the necessary documents for the purchase/registration of the company
  3. Company purchase/registration (takes approximately 5 business day)
  4. Preparation of the company to a form suitable for the license application (up to 7 business days).
  5. Once the company has been registered and provided with all the necessary information and documents, it is possible to apply for a cryptocurrency license.
  6. The application for the issue of a license for activity is processed by the FCIS within 20 working days from the date of submission of the application.

PROCEDURE FOR OBTAINING A CRYPTOCURRENCY LICENCE

Documents required for the application

The following documentation will be required to review and prepare an application for a cryptocurrency licence:

  • Valid copy of passport from home country
  • Power of attorney (PoA) (if the procedure for opening a company and obtaining a license occurs remotely)
  • Company business model/detailed activity description
  • CV/Summary of experience and education of all participants in the crypto related project
  • Website address where cryptocurrency services will be offered
  • Certificate of criminal record (not more than 3 months) for owners, board members, final beneficiaries (UBO) and AML officers
  • Data of all beneficial owners (UBO) must be provided at the request of FCIS

The cryptocurrency company must also have an AML officer. AML officer for the prevention of money laundering and terrorist financing must have previous professional experience and an impeccable reputation (Lithuanian residence is not compulsory).

The licensed company must keep a detailed and up-to-date overview of all customers and transactions in accordance with AML/KYC rules. The FCIS Control Authority can make requests about the company’s activities, especially regarding compliance with the AML/KYC policy.

Risk Assessment, KYC/AML documents and procedural rules

Before applying for a cryptocurrency license in Lithuania, it is necessary to prepare documentation on internal procedures of the company in order to meet the anti-money laundering criteria (AML) and «Know your client» (KYC) established by FCIS. Some parts of this include, for example:

Internal security measures and risk assessments

  • Assessment and risk management of money-laundering and terrorist financing:
  1. Determination of risk level
  2. Risk classification
  3. Nationality
  4. Transaction control procedures
  5. Origin of funds
  6. Compliance monitoring and internal audit
  7. Due diligence measures
  8. Notification obligations
  • Collection and storage of information on company transactions and clients
  • Fulfilling the obligation to notify the regulator
  • Internal control rules of the company

Procedural rules, AML/KYC procedures

  • Description of lower-risk transactions and establishment of appropriate requirements and procedures for such transactions
  • A description of transactions with a higher level of risk, including risks arising from means of communication, location of customers. Other parameters and establishment of appropriate requirements and procedures for conducting and monitoring operations
  • Rules of Due Diligence
  • Customer Identification – document requirements
  • Source of welfare, proof of address of residence
  • Requirements and procedures for storing data on transactions and clients of the company
  • Regulatory Notification Requirements

AML/KYC officer

The duties of an AML employee include:

  • Assistance in the development, implementation and maintenance of an institution’s anti-money-laundering programme.
  • Organization of the collection and analysis of information on suspicious transactions or transactions where there is a risk of money-laundering or the financing of terrorism.
  • Submission of written statements on compliance with the requirements of this Law to the management of the Virtual Currency Exchange Service Provider or Virtual Currency Wallet Service Provider registered in the Commercial Register of Lithuania.
  • High Risk Customer Accounting and Suspicious Activity Reporting.
  • Communication to FCIS in case of suspicion of money laundering or financing of terrorism.
  • Develop and maintain a system of risk assessment for products and services, clients and clients, as well as for other issues related to money-laundering.
  • Monitor and implement a permanent AML learning program for other employees.
  • Guidance and reporting to senior management on issues related to AML’s internal policies and procedures.
  • Organization and conduct of inspections and audits of external organisations, and development of recommendations on compliance with regulatory requirements.

KYC/AML officer applies due diligence measures:

  • When establishing a business relationship with a new client
  • When a cash payment is made in excess of 15,000 EUR or equal to in other currencies
  • When verifying information in case of doubt as to the reliability of the documents or data provided
  • In the case of suspected money laundering or financing of terrorism

FCIS requirements for an AML compliance officer:

  • Only a person who has the education, professional aptitude, abilities, personal qualities, experience and impeccable reputation necessary for the performance of the duties of AML may be appointed as an employee of AML.
  • The company should provide specialized training on measures to prevent money-laundering and the financing of terrorism to its employees, especially those responsible for customer relations and transaction control.

The Compliance Specialist not only tracks and processes various confidential financial data, but also interacts regularly with the board of directors as well as financial authorities. In addition to KYC/AML, an officer of your company must have sufficient authority to ensure the effective performance of his duties. Ideally, an AML specialist should be a director-level employee with industry experience to deal with all aspects of their professional environment.

TAXATION OF CRYPTOCURRENCY COMPANIES IN LITHUANIA

  • Virtual currency exchange services are not subject to VAT.
  • Services provided and accounts paid in virtual currencies are subject to normal VAT rules.
  • The cryptocurrency company’s profits are taxed at a rate of 15%. A micro company with less than ten employees and less than 300,000 euros of gross annual income may be taxed at a reduced corporate tax rate of 0-5%.
  • Income tax (WHT) 15% is levied on distributed profits (dividends paid).

TAXATION OF CRYPTOCURRENCY TRANSACTIONS IN LITHUANIA

The taxation of transactions in virtual currency depends on the nature of the transactions. There is no direct tax if the token is sold or purchased similarly to a security, investment or other currency.

Sales are considered normal/regular, even if payments for goods and services are received in virtual currencies. For accounting purposes, the transaction must have a value in euros and VAT rules are applied according to a normal transaction. Payment of goods or services in virtual currency does not exempt from VAT. If VAT is applied to payments in physical currency, it should also be applied to payments in virtual currency. VAT declarations must be submitted in euros and VAT will be paid / returned in euros.

FCIS

The mission of the Financial Crimes Investigation Service (FCIS) is to protect the public financial system by uncovering criminal acts and other violations of the law.

The purpose of the Financial Crimes Investigation Service is to develop methods of combating criminal activities against the public financial system. In pursuance of this objective, FCIS is actively involved in the implementation of the National Crime Prevention and Control Programme, the National Anti-Corruption Programme, and is preparing a public relations strategy, through which it seeks to involve society in preventive activities against financial crimes. The Service pursues its objective by taking operational measures, detecting and conducting pre-trial investigations and preventing criminal acts, implementing measures to combat money-laundering, as well as the means to guarantee the legality of the receipt and use of financial support from the European Union and other countries, by conducting an assessment of their commercial and financial activities and submitting an expert opinion thereon, as well as measures to ensure that hidden taxes can be reimbursed in order to maximize their impact on the actual revenues to be paid into the State budget.

At present, the Service gives priority to the detection, investigation and prevention of criminal acts related to money laundering, VAT embezzlement, illegal receipt and use of financial support of the European Union and foreign countries. These criminal acts are particularly damaging to the State budget and create a negative image of the State.

Company in Lithuania UAB cooperates with each of our clients individually, and we will prepare the documents based on your information. Please contact our team, and we will offer you the best possible solution for your needs.

FINANCIAL CRIME INVESTIGATION SERVICES OF THE MINISTRY OF THE INTERIOR OF THE REPUBLIC OF LITHUANIA

ON THE ADOPTION OF INSTRUCTIONS TO DEPOSITORY VIRTUAL CURRENCY OPERATORS AND VIRTUAL CURRENCY EXCHANGE OPERATORS ON THE PREVENTION OF MONEY-LAUNDERING AND (OR)  THE FINANCING OF TERRORISM

Approved by Financial crime investigation services under the Republic of Lithuania director of the Ministry of the Interior Order No V-5 of 10 January 2020

INSTRUCTIONS TO DEPOSITORY VIRTUAL CURRENCY OPERATORS AND VIRTUAL CURRENCY EXCHANGE OPERATORS ON THE PREVENTION OF MONEY-LAUNDERING AND (OR) FINANCING OF TERRORISM

Chapter I
GENERAL PROVISIONS 

1. Instructions to Virtual Currency Purse Depository Operators and Virtual Currency Exchange Operators on Preventing Money Laundering and/or Terrorist Financing (hereinafter – «Instructions»)Applicable to monetary operators of generic virtual currencies and operators of virtual currency exchange offices, establishing requirements for the implementation of legislative requirements for the prevention of money-laundering and/or the financing of terrorism and operating procedures of the operator virtual currency purse and virtual currency exchange operator.

2. The concepts used in this document correspond to those defined in the Republic of Lithuania Law on Prevention of Money Laundering and Financing of Terrorism (hereinafter – the Law).

3. The Monetary Operator of Virtual Currency Deposits and the Operator of the Virtual Currency Exchange shall apply the Act in implementing measures to prevent money-laundering and/or the financing of terrorism, Order No V-131 of 12 September 2017 of the Director of the Financial Crimes Investigation Service of the Ministry of the Interior of the Republic of Lithuania (hereinafter – Financial Crimes Investigation Service) «About the description of the approval procedure and the submission of a copy of the identity document». Approval», Order of the Director of the Financial Crimes Investigation Service No V-314 of 30 November 2016 «On Approval of Technical Requirements for Customer Identification Process with Remote Identification by Electronic Means Providing Live Video Broadcasting»The Order of the Director of the Financial Crimes Investigation Service No V-273 on the Proper Application of International Financial Sanctions is the Regulatory Service of the Ministry of the Interior of the Republic of Lithuania and these Instructions.

Chapter II Provisions in chapter I
MEASURES TO COMBAT MONEY-LAUNDERING AND/OR  FINANCING OF TERRORISM

4. The money operator of the virtual currency deposit and the operator of the virtual currency exchange point implement the following measures to prevent the laundering of information/or the financing of terrorism:

4.1. Identification of client and beneficiary:

4.1.1. Determination of whether the client acts on its behalf or is controlled;

4.1.2. If the client acts through a representative, identifying the client’s representative;

4.1.3. Identification of the customer as an individual;

4.1.4. Identification of the client as a legal person;

4.1.5. Identification of the client’s beneficiary as a legal person;

4.1.6. Collection of information on the client management legal entity;

4.1.7. Collection of information on the ownership and control structure and nature of the client’s business as a legal entity;

4.1.8. Gathering information on the purpose and intended nature of the customer’s business relationship, whether natural or legal;

4.1.9. Verification of the identity of the client and beneficiary on the basis of documents, data or information obtained from a reliable and independent source; 4.1.10.1 Continuous monitoring of the client’s business relationship;

4.1.11.1. Continuous review and updating of documents, data or information provided by the client and beneficiary in the identification;

4.2. Where it is not possible to meet the requirements for identification of the applicant and of the debtor, failure to perform the transactions, failure to establish the business relationship,  Termination;

4.3. Application of customer and beneficiary identification tools not only to innovations but also to existing clients (Clients who became clients of the virtual currency purse operator and the virtual currency exchange operator before 10 January 2020, these measures are applied on the basis of their level of risk, starting with clients with higher risk, without delay but not later than 1 July 2020);

4.4. Suspension of the suspicious monetary transaction or transaction;

4.5. Reporting of suspicious monetary transactions or transactions;

4.6. Notification of virtual currency or virtual currency transactions if the value of such monetary transaction or transaction is equal to or greater than 15,000 EUR or the foreign or virtual currency equivalent, whether the transaction is in one or more related monetary transactions;

4.7. Examining the structure of complex or abnormally large transactions and unusual transactions;

4.8. Storage of information for a certain period of time;

4.9. Designation of officials responsible for implementing measures to combat money-laundering and/or the financing of terrorism;

4.10. Training of staff;

4.11. Introduce internal systems to respond promptly to requests from the Financial Crimes Investigation Service through secure channels and to ensure full confidentiality of requests;

4.12. Confidentiality of information provided to the Financial Crimes Investigation Service;

4.13. Establishment of internal policies and procedures for internal control; 4.14.Provide information on the beneficiaries of the depository currency of the money operator and the operator of the virtual currency exchange point to the Administrator of the Information System of Legal Participants (JADIS).

Chapter III Provisions in the first chapter
IMPLEMENTATION OF MEASURES AGAINST MONEY-LAUNDERING AND/OR THE FINANCING OF TERRORISM

FIRST SECTION
IDENTIFICATION OF CLIENT AND BENEFICIARY

5. The monetary operator of the virtual currency deposit and the operator of the virtual currency exchange should take steps to identify and verify the identity of the client and the recipient:

5.1. Before entering into a business relationship;

5.2. Before performing a single (one-time) virtual currency exchange operation or a one-time (2007) transaction. From time to time, transactions in virtual currency with funds equal to or exceeding €1,000 or the corresponding amount in foreign or virtual currency, or by a one-time transaction (EUR 1,000). From time to time, deposit in the deposit book or one-time ($100 million) virtual currency. From time to time, the withdrawal of a virtual currency for an amount equal to or greater than €1,000 or a corresponding amount in foreign or virtual currency, regardless of whether the transaction is in one or more interrelated transactions (the value of the virtual currency is determined at the time of the monetary transaction or transaction) if the client and beneficiary are no longer identified;

5.3. Where there is doubt as to the correctness or authenticity of the previous identification of the client and the beneficiary;

5.4. In any other case where money-laundering and/or the financing of terrorism is suspected to occur, have occurred or will occur.

6. The monetary operator of the virtual currency deposit and the operator of the virtual currency exchange carry out the identification of the client and the beneficiary in accordance with the provisions of articles 9 to 15 of the Law, using a risk-oriented approach using:

6.1. Normal means and procedures for customer identification;

6.2. Additional tools and procedures for customer identification to conduct enhanced customer identification;

6.3. Simplified customer identification tools and procedures to facilitate customer identification.

7. In such cases where the monetary operator of the virtual currency deposit and the virtual currency exchange operator are unable to comply with the requirements set out in paragraphs 4.1.1 to 4.1.10 of these instructions, the monetary operator of the deposit of virtual currencies and the operator of the virtual currency exchange shall comply with the prohibition on conducting transactions through bank accounts set out in article 9, paragraph 18, of the Law, to establish or continue business relationships, conduct operations and assessments of the threat of money-laundering and/or the financing of terrorism. Having identified the threat of money laundering and/or terrorist financing, the money operator of the deposit of virtual currencies and the operator of the virtual currency exchange office report the suspicious money transaction or transaction to the Financial Crime Investigation Service.

SECTION II
SIMPLIFIED CUSTOMER IDENTIFICATION

8. If the Virtual Currency Deposit Operator and the Virtual Currency Exchange Point Operator seek to apply a simplified identification of the customer in the cases provided for in article 15, paragraph 1, of the Law, they must conduct a risk assessment and have evidence of: that a low risk of money laundering and/or terrorist financing has been identified. Risk assessment data are stored in the same order as other data received at the time of customer identification.

9. The money operator of the virtual currency deposit and the operator of the virtual currency exchange point are obliged to regularly monitor the customer’s business relations, including by assessing whether the risk of money laundering and/or terrorist financing by the client remains low.

THIRD SECTION
IMPROVED CUSTOMER IDENTIFICATION

Politically vulnerable (vulnerable) persons

10. When the client – natural person or client – beneficiary of a legal entity is politically vulnerable (exposed) person, the money operator of the deposit
the virtual currency and the operator of the virtual currency exchange point are obliged to apply the measures specified in article 14, paragraph 3, of the Law.

11. The monetary operator of the Virtual Currency Depository and the Virtual Currency Exchange Point Operator determine in internal control policies and procedures what measures they apply during when a politically exposed person ceases to perform important public duties until it is established that the person no longer poses a risk to politically vulnerable persons (for at least 12 months). Risk assessment data are stored in the same order as other data received at the time of customer identification.

Third high-risk countries

12. If the client, an individual or client beneficiary of a legal entity, resides in a third high-risk country or where the client is a legal entity established in a third high-risk country, The monetary operator of the depositary virtual currency and the operator of the virtual currency exchange point shall apply the measures set out in article 14, paragraphs 1 and 5, of the Act.

13. European Commission Regulation (EU) No 2016/1675 of 14/07/2016 establishes the list of third high-risk countries with the European Commission, published in the section «International Law» of Chapters www.fntt.lt on Prevention of Money Laundering on the web.site and database EUR-Lex https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016R1675 of European Union legislation.

14. The list of high-risk third-party Financial Action Task Force on Money Laundering and Financing of Terrorism (FATF) is published in the section «FATF Statements» of the www.fntt.lt website and on the FATF website https://www.fatf-gafi.org/countries/ and https://ww.fatf-gafi.org/coun tries/#high-risk.

15. In order to ascertain whether transactions or dealings are conducted with individuals residing in high-risk countries or with legal entities, The Virtual Currency Depository Cash Operator and the Virtual Exchange Point Operator shall check both lists of high-risk third countries referred to in paragraphs 13 and 14 of these Instructions.

16. In the cases provided for in article 14, paragraph 5, of the Act, the monetary operator of the virtual currency deposit and the operator of the virtual currency exchange point shall be defined in internal policies and procedures of internal control, What or some additional measures of customer and beneficiary identification are taken at their discretion to mitigate risks, such as:

16.1. Obtain additional information on the client and beneficiary;

16.2. Obtain additional information on the expected nature of the business relationship;

16.3. Obtain information on the source of funds and assets of the client and the beneficiary;

16.4. Obtain information on the reasons for transactions planned or carried out;

16.5. Obtain the approval of a senior manager to establish a business relationship with these customers or consent to continue business with these customers;

16.6. Strengthen continuous monitoring of business relationships with these customers by increasing the number and duration of controls and the types of transactions that will require further investigation;

16.7. Guarantee that the customer’s first payment is made from the customer’s account in a credit institution where the credit institution is registered in a Member State of the European Union or in a third country which has requirements equivalent to those of established by this Law and the competent authorities shall monitor compliance with these requirements.

17. If the money operator of the Virtual Currency Deposit and the Virtual Exchange Point Operator apply the derogation specified in Article 14(1)(3) of the Act, to subsidiaries or subsidiaries of financial institutions or other liable persons established in the European Union, The monetary operator of the depository virtual currencies and the operator of the virtual exchange point should conduct a risk assessment and have evidence that the risks identified are not significant. Risk assessment data are stored in the same order as other data received at the time of customer identification.

Increased risk of money-laundering and/or terrorist financing

18. When the monetary operator of the virtual currency deposit and the operator of the virtual exchange point determine, in accordance with risk assessment and management procedures, a higher risk of money-laundering and/or terrorist financing, The monetary operator of the deposit virtual currencies and the operator of the virtual currency exchange point shall apply the measures set out in article 14, paragraph 5, of the Law.

19. The monetary operator of the depositary virtual currency and the operator of the virtual currency exchange point determine in internal policy and internal control procedures, Which of these are being implemented, at their discretion, one or more additional measures to identify the client and beneficiary to mitigate emerging risks, such as:

19.1. Obtain additional information on the client and beneficiary;

19.2. Obtain additional information on the expected nature of the business relationship;

19.3. Obtain information on the source of funds and assets of the client and the beneficiary;

19.4. Obtain information on the reasons for planned or implemented transactions;

19.5. Obtain the approval of a senior manager to establish a business relationship with these customers or consent to continue business relations with these customers;

19.6. Strengthen the continuous monitoring of business relationships with these customers by increasing the number and duration of controls and selecting types of transactions that will require further investigation;

19.7. Guarantee that the customer’s first payment is made from the customer’s account in a credit institution where the credit institution is registered in a Member State of the European Union or in a third country which has requirements, equivalent to those established in this Law and the competent authorities shall monitor compliance with these requirements.

20. Risk assessment data are stored in the same order as other data from the moment of identification of the client.

CHAPTER FOUR
MONITORING OF BUSINESS RELATIONS

21. When a business relationship with a client begins, the monetary operator of the virtual currency deposit and the operator of the virtual exchange office must monitor the business relationship to ensure that the transactions made correspond to the information, available to virtual currency depository, money operator and operator of virtual exchange about the client, its business, risk profile and source of funds.

22. Virtual Currency Cash Deposit Operator and Virtual Currency Exchange Point Operator classify clients with whom a business relationship has been established as risk according to the criteria and procedures for assigning clients to risk groups, as set out in their internal policies and procedures for internal control.

CHAPTER FIVE
SUPPRESSION OF SUSPICIOUS TRANSACTIONS OR OPERATIONS AND REPORTING TO THE FINANCIAL CRIMES INVESTIGATION SERVICE

23. The money operator of the deposit of virtual currencies and the operator of the virtual currency exchange item, in accordance with Article 16 of the Law, suspend the suspicious monetary transaction or transaction if this is objectively impossible.

24. Suspicious monetary transactions or transactions must be detected:

24.1. Taking into account the criteria for detecting suspicious monetary transactions or transactions approved by order of the Director of the Financial Crimes Investigation Service No V-240 of 5 December 2014 on the adoption of a list of criteria for money-laundering and the detection of suspicious monetary transactions or transactions;

24.2. Drawing attention to customer activities that by their very nature may be related to money laundering and/or the financing of terrorism;

24.3. Identification of the client and the beneficiary;

24.4. Continuous monitoring of the customer’s business relationship, including investigation of transactions made in the course of the relationship.

25. Monetary Operator of Deposited Virtual Currencies and Operator of Virtual Currency Exchange are obliged under Article 16 of the Law to notify the Financial Crimes Investigation Service of information on suspicious money transactions or transactions not later than in within 3 working hours.

26. Suspicious money transactions or transactions are reported regardless of the size of the money transaction or transaction.

27. The Virtual Currency Exchange Operator notifies the Financial Crimes Investigation Service, in accordance with article 20 of the Act, of the identity of the client and the information on the virtual currency exchange operation carried out (purchase or sale of virtual currency in the currency of the decree) or transaction in virtual currency (payments in virtual currency for assets) if the value of such monetary transaction or transaction is equal to or greater than EUR 15,000 or equivalent. Foreign currency or virtual currency, whether the transaction is in the form of one or more interrelated monetary transactions. The value of a virtual currency is determined at the time of a money transaction or transaction.

28. Where a money transaction or a transaction of a customer satisfies both the characteristics of paragraph 24 and paragraph 27 of this Instruction, the money operator of the depository virtual currency and the operator of the virtual currency exchange office must submit to the Financial Crimes Investigation Service both reports, or a report of a suspicious money transaction or transaction, or a notification of a virtual currency exchange transaction or a virtual currency transaction, provided that the value of such monetary transaction or transaction is equal to or equal to the value of the transaction; exceeds EUR 15,000 or the equivalent in foreign or virtual currency, whether the transaction is one or more linked monetary transactions.

29. Notifications to the Financial Crimes Investigation Service are made in accordance with the Order of the Minister of Internal Affairs of the Republic of Lithuania No 1V-701 of 16 October 2017 On suspending suspicious monetary transactions or transactions and submitting information on suspicious monetary transactions or transactions to the Financial Crimes Investigation Service of the Ministry of Internal Affairs of the Republic of Lithuania and information on cash transactions or deals, whose amount is equal to or greater than 15,000 euros or the corresponding amount in foreign currency, approval of the procedure of the Financial Crimes Investigation Service under the Ministry of the Interior of the Republic of Lithuania», Order No V-129 of 21 May 2015 of the Director of the Financial Crimes Investigation Service On the forms of provision of information, provided in accordance with the requirements of the Law of the Republic of Lithuania on Prevention of Money Laundering and Financing of Terrorism, the scheme of submission and acceptance of recommendations for completion of the submission forms”.

CHAPTER SIX
STORAGE OF INFORMATION AND DOCUMENTS

30. The money operator of the deposit of virtual currencies and the operator of the virtual currency exchange should keep the following logs:

30.1. Register of reports and suspicious monetary transactions and transactions specified in article 16, paragraph 1, of the Act;

30.2. Journal of monetary transactions performed by the client referred to in article 9, paragraph 1, paragraphs 2 to 6, of the Act;

30.3. Virtual currency or virtual currency transactions, provided that the value of such monetary transaction or transaction is equal to or greater than 15,000 euros or the foreign or virtual currency equivalent, whether the transaction is in the context of one or more related monetary transactions;

30.4. Register of clients with whom transactions or business dealings have been terminated in the circumstances specified in article 18 of the Act or in other circumstances related to violations of the procedure for preventing money laundering and (or)  financing of terrorism.

31. Data shall be entered in the registers in chronological order without delay and not later than within 3 working days from the time of the money transaction or transaction.

32. The monetary operator of the virtual currency deposit and the operator of the virtual currency exchange give priority to the electronic storage of the log’s registration data.

33. The registers are kept in accordance with Order No V-129 of 4 September 2017 of the Director of the Financial Crimes Investigation Service of the Ministry of the Interior of the Republic of Lithuania «On approval of rules of processing of money transactions, transactions and registers of clients».

SECTION SEVEN
EMPLOYEES

34. The money operator of the virtual currency depository and the operator of the virtual currency exchange should appoint management staff to organize the implementation of measures to prevent money-laundering and the financing of terrorism and to liaise with the Investigation Service of financial crimes. If the monetary operator of the virtual currency deposit and the operator of the virtual exchange point are managed by the board, The monetary operator of the depositary virtual currencies and the operator of the virtual exchange point shall appoint a member of the Council to organize the implementation of the measures against money-laundering and / or the financing of terrorism set forth in this Law, and management personnel to cooperate with the Financial Crimes Investigation Service. These officers should be notified in writing q to the Financial Crimes Investigation Service by the Virtual Currency Money Operator and the Virtual Exchange Point Operator. The monetary operator of the virtual currency deposit and the operator of the virtual currency exchange point should ensure that said employees have access to all information necessary for the performance of their functions, including access to information, related to customer and beneficiary identification, customer business relations monitoring, money transactions and transactions.

35. The money operator of the depository virtual currency and the operator of the virtual exchange point should provide specialized training to their employees on measures to combat money-laundering and / or the financing of terrorism, especially for those who work directly with clients and their transactions.

CHAPTER EIGHT
INTERNAL CONTROL PROCEDURES

36. The monetary operator of the Virtual Currency Deposit and the Virtual Currency Exchange Point Operator should specify in detail in the internal policy and internal control procedures, How the money operator of the depositary virtual currencies and the operator of the virtual currency exchange point are to implement the measures referred to in article 29, paragraph 1, of the Law.

37. To effectively manage the risks of money-laundering and terrorist financing, the virtual currency purse operator and the virtual currency exchange operator must assess the risk of money-laundering and terrorist financing of all their activities at least once per year, with the latest information.

38. All risk assessments of all money-laundering and terrorist financing activities carried out by the Virtual Currency Purse Operator and the Virtual Currency Exchange Point Operator and subsequent changes related to this risk assessment, must be documented in writing.

39. The monetary operator of the virtual currency deposit and the operator of the virtual currency exchange point should review and, if necessary, update internal control procedures:

39.1. Publication by the European Commission of a pan-European assessment of the risks of money-laundering and the financing of terrorism (available on the European Commission website ec.europa.eu);

39.2. Publication of the results of the National Assessment of the Risks of Money Laundering and Terrorist Financing (published in the section «Prevention of Money Laundering wwww.fntt.lt in the subsection «National Assessment of the Risks of Money Laundering and Terrorist Financing»);

39.3. Strengthen the applicable internal control procedures as directed by the Financial Crimes Investigation Service;

39.4. In the event of significant events or changes in the management and operation of the virtual currency depository of the money operator and the virtual currency exchange operator;

39.5. Periodic monitoring of the implementation and adequacy of internal control procedures.

Chapter IV Provisions in chapter I
IMPLEMENTATION OF INTERNATIONAL FINANCIAL SANCTIONS

40. The monetary operator of the virtual currency deposit and the operator of the virtual currency exchange office must, in each specific case, before entering into a relationship with the client or entering into a transaction, ensure that the client, the beneficiary and/or the client’s representative are not included in the lists of persons, subject to international financial sanctions.

41. The consolidated list of sanctions of the European Union is published on the European Commission website https://eeas.europa.eu/topics/sanctions-policy/8442/consolidated-list-sanctions_en.

42. The United Nations consolidated list of sanctions is published on the United Nations website https://www.un.org/sc/suborgen/sanctions/un-sc consolidated-list.

43. In order to verify that transactions are not carried out, business relations are not maintained or established with persons subject to international financial sanctions, and it is necessary to check the lists of persons, which are subject to international financial sanctions, both in the European Union and in the United Nations, in order to verify that there are no transactions.

44. The money operator of the virtual currency deposits and the operator of the virtual currency exchange office shall comply with the Law of the Republic of Lithuania on the Implementation of Economic and Other International Sanctions, Regulations of the Government of the Republic of Lithuania on the Implementation of International Sanctions, Regulations of the European Union on International Sanctions and Exemptions from their Application and Order No V273 Directors of the Financial Crimes Investigation Service, dated 20 October 2016, on the appropriate requirement for the approval of oversight instructions for the implementation of international financial sanctions in the area of the regulation of the Financial Crimes Investigation Service Ministry of the Interior of the Republic of Lithuania.

CHAPTER V
FINAL PROVISIONS

45. The provisions of the amended Laws of the Republic of Lithuania, Government Decrees and other legal acts must be implemented immediately, without waiting for these Instructions to be amended or supplemented.

46. The monetary operator of the deposit of virtual currencies and the operator of the virtual currency exchange, having violated the requirements of these instructions, shall be liable in the manner prescribed by law.

47. Virtual Currency Money Operator and Virtual Exchange Point Operator for Prevention of Laundering and/or Financing of Terrorism, are requested to check the quality of implementation of measures through a self-monitoring questionnaire (Annexes)which is a help in meeting the requirements.

Measures to combat money-laundering and/or the financing of terrorism

1. Before entering into a business relationship; (k), the customer performs virtual currency exchange or virtual currency transactions with funds equal to or exceeding 1,000 Euro or foreign or virtual currency equivalent, or before making a deposit or withdrawal of a virtual currency with an amount equal to or greater than €1,000 or a corresponding amount in foreign or virtual currency, whether the transaction is in the context of one or more interrelated transactions (The value of the virtual currency is determined at the time of the monetary transaction or transaction) if the identity of the client and beneficiary is not established; If there is doubt as to the correctness or authenticity of the previously obtained identity of the client and beneficiary; in any other case,  if there is a suspicion that there is, money laundering and/or the financing of terrorism has been or will be carried out, The client and the beneficiary shall be identified:

1.1. Determine whether the client is acting on his behalf or is under control

1.2.  A copy of the identity document or residence permit in the Republic of Lithuania is made or the document is scanned

1.3. Verification of circumstances for the extended identification of clients

1.4. The identity of the client – natural person is established; a copy of the identity or residence permit in the Republic of Lithuania is made or the document is scanned

1.5. Identification of client – legal entity

1.6. Identify the client’s beneficiary as a legal person

1.7. Collects information on the head of the client’s legal entity

1.8. Collection of information on the ownership and control structure and client nature of the legal entity

1.9. Collects information on the purpose and intended nature of the client’s business relationship – natural or legal person

1.10. The identity of the client and beneficiary is verified on the basis of documents, data or information obtained from a reliable and independent source

1.11. Constant monitoring of the customer’s business relations

1.12. Continuous review and updating of documents, data or information provided by the client and beneficiary at the time of identification

2. Transactions are not carried out, business relationships are not established, they are terminated if it is impossible to carry out the identification of the applicant and the beneficiary

3. The customer and beneficiary identification tools apply not only to novelties, but also to existing customers

4. Suspicious monetary transaction or transaction made by the client is suspended if objectively impossible.

5. Suspicious money transactions or transactions shall be reported to the Financial Crimes Investigation Service within 3 working hours at the latest.

6. The virtual exchange operator shall, within 7 working days at the latest, report to the Financial Crimes Investigation Service on the exchange of virtual currency or transactions in virtual currency, If the value of such monetary transaction or transaction is equal to or greater than EUR 15,000 or the foreign or virtual currency equivalent, regardless of whether the transaction is in the form of one or more interconnected money.

7. Monitor and work with complex or unusually large transactions and unusual transaction structures

8. Records and information shall be kept no later than 3 working days.

9. Information is kept for 8 years (correspondence of business relationship with client – 5 years)

10. An officer has been appointed to implement measures to combat money-laundering and/or the financing of terrorism, as reported in writing to the Financial Crimes Investigation Service.

11. In-service training of staff

12. Internal systems are in place to respond quickly to requests from the Financial Crimes Investigation Service through secure channels and full confidentiality of requests.

13. Information provided to the Financial Crimes Investigation Service is protected

14. Periodic risk assessment and response to money-laundering and/or terrorist financing by client, product, geographical region to mitigate these risks

15. Established internal policies and procedures for internal control

16. Information on the beneficiaries of the deposit of the virtual currency operator and the operator of the virtual currency exchange point is available to the Manager of the Information System of Participants of Legal Entities (JADIS)

17. Measures to implement financial sanctions

Frequently asked questions

  • Does Lithuania grant a licence for crypto activities?
    Yes, a Lithuanian company may apply for a licence for cryptographic activities under the Order on instructions to deposit operators for virtual currency money monitors and operators for virtual currency exchanges for the prevention of money laundering and / or financing. The purpose of the Law is to prevent the use of Lithuania’s financial system and economic space for money laundering and terrorist financing by increasing the reliability and transparency of the business environment. This Law regulates the principles of assessment, management and hedging of risks related to money-laundering and the financing of terrorism, supervision of responsible persons, obligations arising from the collection and publication of data of beneficial owners, Obligations related to the collection and publication of data on the holders of payment accounts, liability of the persons liable in case of violation of the requirements arising from the legislation.
  • How do I get a crypto license in Lithuania?
    In order to get a crypto-license in Lithuania, it is first necessary to establish/ buy a ready-made company in Lithuania. Once the company has been re-registered in your name, you can apply for a cryptocurrency license (Cryptocurrency exchange license or Crypto wallet and custodian services license) by notifying Lithuanian Financial Crime Investigation Service about the crypto activity (FCIS). An electronic member of the board of a company may apply for a cryptocurrency licence in Lithuania. A crypto license in Lithuania is issued for an indefinite period.
  • Is it necessary to contact Lietuvos Bankas in cryptographic activities on behalf of a Lithuanian company?
    No, the Lithuanian Financial Crime Investigation Service (FCIS) regulates the activities of cryptocurrency companies in Lithuania
  • What are the activities of the crypto license in Lithuania?
    The crypto license in Lithuania is divided into two activities:
    Cryptocurrency exchange license (cryptocurrency exchange license). A company with such a license may exchange the digital currency for FIAT or vice versa, or a cryptocurrency for another cryptocurrency, receiving a commission for the services provided.
    Crypto wallet and custodian services license (cryptocurrency and customized services license). A company with such a license can use the client’s purse to store the cryptocurrency, including creating and storing encrypted client keys.
  • How long does it take to get a license?
    The first step for obtaining a crypto-license in Lithuania is the establishment/purchase of a company in Lithuania. It is important to remember that the company’s charter capital (at least 2,500 euros) must be paid. Once you have become the owner of the company, you must notify Registrų centras of the cryptographic activity of the company. Under article 25, paragraph 4 The Law on Prevention of Money Laundering and Financing of Terrorism, a legal person who has started the activities of a virtual currency exchange operator or a virtual currency purse holder within five working days at the latest, must inform Registrų centras about the activity of the service provider of the virtual currency exchange operator and the operator of the virtual currency-custodian purse.By providing this information, the virtual currency exchange operator and the virtual currency custodian’s wallet operator must confirm that he or members of his administration or supervision, and the beneficial owners are familiar with and comply with the requirements of legal acts to prevent money-laundering and the financing of terrorism. Only then can you contact Lithuanian Financial Crime Investigation Service (FCIS) and provide all necessary documents.
  • Can non-residents of Lithuania own a crypto company?
    Yes, non-residents of Lithuania may be rightful owners of a Lithuanian crypto company but it is worth bearing in mind that non-residents of Lithuania will have to provide an extended package of documents, including a certificate of no criminal record from the country of residence.
  • Can non-residents of Lithuania be part of the board of a Lithuanian crypto company?
    The board of the Lithuanian cryptocurrency company may include non-residents of the country. It should be borne in mind that the board of the virtual currency exchange operator and the operator of the virtual currency depository cannot include natural persons who have previously been convicted of a crime and have a valid criminal record that has not been annulled.
  • Is it necessary to have a banking account to obtain a licence?
    Yes, an account with a financial institution registered in Lithuania (one of the Lithuanian banks or the Electronic Money Institution registered in Lithuania) must be opened with a company applying for a crypto license. The company’s authorized capital must be deposited into this account.
  • What is the minimum authorized capital for a virtual currency service provider?
    The minimum authorized capital is 2500 EUR. The authorized capital must be paid in full before the application is submitted. It is only possible to deposit the authorized capital for a cryptocurrency company with a deposit from the owner/owners' personal account in the account of the company in one of the banks of Lithuania or Electronic Money Institution registered in Lithuania.
  • For how long is a crypto-license issued?
    A crypto license in Lithuania is issued for an indefinite period.
  • Is it possible to deposit authorized capital in cryptocurrency?
    No, it is only possible to deposit the charter capital for a cryptocurrency company by a money deposit from the owner/owners' personal account into the account of the company in one of the banks of Lithuania or the Electronic Money Institution registered in Lithuania.
  • How is the charter capital of a crypto company paid in?
    The authorized capital is paid by means of a monetary contribution (bank transfer). The owners of the company contribute capital at the nominal value of their share (i.e. corresponding to their share in the authorized capital). Payment is made from the bank account of the member of the board to the bank account of the company in one of the banks of Lithuania or Electronic Money Institution registered in Lithuania.
  • What happens next with the money investment in the corporate account of the Lithuanian crypto company?
    The amount contributed can be used for the commercial activity of your company crypto after the Registrų centras of Lithuania confirms the deposit of the charter capital of the company.
  • When do you need to deposit capital to open a company and obtain a crypto-license in Lithuania?
    The full payment of the charter capital of the crypto-company (2,500 EUR) is mandatory before applying for a crypto-license in Lithuania. The authorized capital must be paid at the time the company is established in Lithuania. The amount paid can be further used to finance the company’s crypto business in Lithuania.
  • What does a crypto company need to apply for a cryptographic license in Lithuania?
    The conditions for applying for a cryptocurrency licence are:
    • Procedural melting and risk assessment procedures
    • Capital paid (at least 2,500 EUR)
    • Availability of KYC/AML officer with impeccable reputation.
    • Certificate of absence of criminal records from all company members
    • CV all project participants with key positions in the company
  • Why you should get a crypto license in Lithuania?
    Nothing attracts entrepreneurs like the speed and cost of launching the project, and in Europe, Lithuania is now the most favorable jurisdiction for launching a cryptocurrency project. The legalization of crypto activities in Lithuania will require one or two cryptocurrency licences, which can be obtained within one month, which strengthens its position among the most convenient and preferred jurisdictions for the launch of the blockchain project. The financial costs of the legal part in Lithuania are also significantly lower than in other European countries. A comparison of the European jurisdictions in which cryptographic activity is legalized can be found here.
  • Are Lithuanian cryptocurrency companies audited?
    Yes. The physical office can be visited by the regulator at any time to check the documentation and confirm the company’s activities. The regulator can also request information on any client of the crypto project. All clients must have information is held for at least five years from the date of the last transaction and must be available for distribution to the regulator on request no later than two business days.
  • Can the director of a crypto company be a non-resident of Lithuania?
    Yes, a director of a company may not be a resident of Lithuania if he possesses the necessary skills and corresponds to the position and has an impeccable reputation.
  • What measures to prevent money-laundering and the financing of terrorism are in place in Lithuania?
    The Virtual Currency Deposit Service Provider and the Virtual Currency Exchange Company should take the following measures to prevent money laundering and / or the financing of terrorism: Identification of client/recipient of funds:
    • Determination of whether the client acts on his or her behalf or through a representative
    • If the client acts through a representative, identifying the client’s representative
    • Identification of the recipient - natural person
    • Identification of the client - legal person
    • Identification of the client, beneficiary of the legal entity
    • Collection of information about the client, member of the legal entity
    • Collection of information on the structure of the legal person and the nature of the activity; Collection of information on the purpose and intended nature of the client’s business relationship with the recipient of the funds, whether a natural or a legal person
    • Verification of the identity of the client and the recipient on the basis of documents, data or information obtained from a reliable and independent source
    • Continuous monitoring of the customer’s business relations
    • Regular review and updating of documents, data or information provided in the identification of the client and the recipient of funds
    • If it is impossible to fulfil the requirements for identification of the client and the recipient of funds - suspension of the transaction, and if it is impossible to establish a business relationship, termination of the cooperation
    • Application of customer and recipient identification measures not only to new but also to existing clients of the company (clients who became clients of the virtual currency operator and virtual currency exchange operator before )
    • Suspending suspicious money transactions or cryptocurrency transactions; ~- Notifying suspicious money transactions or FCIS transactions
    • Notice of virtual currency exchange transactions or transactions in virtual currency, if the amount of such monetary transaction or transaction is equal to or greater than EUR 15,000 or its equivalent in foreign or virtual currency, regardless of whether the transaction is in one or more related money transfers
    • A detailed examination of complex or unusually large transactions
    • Storage of information for a certain period of time
    • Appointing officials responsible for implementing measures to prevent money-laundering and / or the financing of terrorism
    • Training of staff
    • Introduction of internal systems to respond promptly to requests from the Financial Crimes Investigation Service through secure channels and to ensure full confidentiality of requests
    • Establish internal internal control policies and procedures
  • When are measures to prevent money-laundering and the financing of terrorism applied in Lithuania?
    The virtual currency depository wallet operator and the virtual currency exchange operator must take steps to identify and verify the identity of the client and the recipient: - Before starting a business relationship with the client; - Prior to a single exchange of virtual currency in an amount equal to or greater than EUR 1,000 or its foreign/virtual currency equivalent, whether the transaction is one or more related transactions (The value of the virtual currency is determined at the time of the money transaction Where there is doubt as to the accuracy or authenticity of the identification information previously received by the client and the recipient of the funds; - in any other case where there is a suspicion that there is a risk of money laundering and / or financing of terrorism. The Virtual Currency Depository Wallet Operator and the Virtual Currency Exchange Operator identify the client and the recipient of the funds in accordance with the provisions of Articles 9 to 15 of the Law, applying a risk-based approach, using: - The usual means and procedures for identifying the customer; Additional tools and procedures for customer identification to enhance customer identification; - Simplified means of customer identification and procedures for performing simplified customer identification. - in such cases where the virtual currency depository wallet operator and the virtual currency exchange operator are unable to meet the requirements, In sub-paragraphs 4.1.1-4.1.10 Order on instructions to deposit operators for virtual currency money monitors and operators for virtual currency exchanges for the prevention of money laundering and / or financing, shall refuse to cooperate. If a threat of money laundering and / or financing of terrorism is detected, the Virtual Currency Depository Wallet Operator and the Virtual Currency Exchange Point Operator must notify the Financial Crime Investigation Service of a suspicious money transaction.
  • How can Company in Lithuania UAB help in obtaining a crypto license?
    Our company has extensive experience in obtaining cryptocurrency licenses in Lithuania and is ready to accompany you throughout the licensing process. We will help in the establishment or purchase of a company in Lithuania that meets the requirements of the regulator, we will help with drawing up procedural rules and risk assessment, AML/KYC documents. Also Company in Lithuania UAB can help in finding and employing a Lithuanian KYC/AML officer for your company and train it in customer identification requirements under the Law on Prevention of Money Laundering and Financing of Terrorism.It should be noted that the selected employee will be a member of your company only, which is in accordance with the non-competitive clause and will represent it with the regulator. In addition, our employees can choose an office that fully complies with your company’s requirements and help with opening a bank account to deposit capital and open an account for working with crypto exchanges. Company in Lithuania UAB specialists will be glad to keep you up to date with all the latest changes in Lithuanian legislation and are always ready to answer all your questions.
  • What difficulties may arise in obtaining a crypto license in Lithuania?
    The most common problem today is the revocation of the licences of crypto companies that, in the process, have changed their owners and have not notified the regulator. Another common problem is the incompatibility of the KYC/AML officer with the position and his inability to properly perform his duties.
  • Where can I open a bank account for a Lithuanian crypto company?
    The opening of a bank account for a high-risk company, which is cryptocurrency, is a complex and sensitive issue. It is worth taking into account the fact that not every bank of Lithuania cooperates with companies of such activities, and buying a company with an open bank account is impossible. Our company has partner banks all over Europe that are ready to work with cryptocurrency, and we will be happy to accompany our clients in opening an account. Company in Lithuania UAB offers a wide range of additional services, such as accounting services for cryptocurrency companies, tax advice, financial licenses (EMI, Payment institution) and employment assistance (KYC/AML officer). For us the individual approach to each of our clients is important. We take care of the needs of your business, combining individual order processing as well as professional consultations, reasonable rates and company registration services in Lithuania for customers from all over the world. Besides, Company in Lithuania UAB provides support to entrepreneurs in accordance with the latest innovations of Lithuanian legislation throughout the life of their companies.
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