KYC/AML Officer in Lithuania

Within the fight against financial crimes, governments around the world require their financial institutions to implement anti-money laundering (AML) programs. In order to monitor domestic anti-money laundering policies and comply with important regulations, banks and other financial institutions undertake to appoint a specialist in compliance with anti-money laundering requirements – KYC/AML officer.

Lithuanian companies providing regulated crypto-asset services must comply with the AML/CFT obligations applicable to Crypto-Asset Service Providers (CASPs) under Lithuanian legislation and EU Regulation 2023/1114 (MiCA). This includes appointing appropriately qualified personnel responsible for AML/CFT compliance, establishing internal controls and ensuring effective suspicious transaction reporting. Lithuania’s former national VASP registration regime ended on 31 December 2025. Since 1 January 2026, companies must generally hold the appropriate MiCA authorisation or qualify for an applicable alternative regulatory procedure before providing regulated crypto-asset services.

The Bank of Lithuania is the competent authority responsible for the authorisation and prudential supervision of Crypto-Asset Service Providers (CASPs) under MiCA. The Financial Crime Investigation Service (FNTT, also referred to as FCIS in English) retains responsibilities relating to financial intelligence, suspicious transaction reporting and AML/CFT supervision within its statutory competence. Crypto-asset businesses must comply with the requirements of both authorities where applicable.

Requirements for the implementation of AMTF prevention measures are laid down in the Law

According to the legislation of Lithuania, Virtual Currency Exchange Operators and Virtual Currency Depository Purse Operators are required to appoint senior officers to organize the implementation of measures to prevent money laundering and/or the financing of terrorism, The Criminal Investigation Service (hereinafter referred to: FCIS) is responsible for the investigation of offences under the Act. Where virtual currency exchange operators and virtual currency purse depository operators are headed by the board of directors, financial institutions and other liable entities, Appoint a member of the Council for the Organization of the Implementation of the Measures for the Prevention of Money Laundering and/or Financing of Terrorism specified in the Law and senior officers to liaise with the FCIS. Under Article 22 of the Lithuanian Law on the Prevention of Money Laundering and Terrorist Financing, financial institutions and other obliged entities must notify the Financial Crime Investigation Service (FNTT) in writing of the appointment or replacement of designated senior employees responsible for AML/CFT implementation and cooperation with FNTT. Where the institution has a management board, the applicable notification obligation also covers the designated board member. The notification must be submitted no later than seven working days after the appointment or replacement. These individuals are appointed by the obliged entity, not by FNTT.

A Lithuanian obliged entity must notify FNTT of the appointment or replacement of the designated AML/CFT responsible persons in accordance with Article 22 of the Lithuanian AML Law. The notification must include the identification and contact information required by FNTT and must be submitted through the officially designated communication channel within seven working days. Appointment of an AML officer does not replace the regulatory authorisation or governance requirements applicable to a MiCA-authorised CASP.

RESPONSIBILITIES OF KYC/AML OFFICER

• Assistance in the development, implementation and maintenance of the 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 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 the virtual currency purse provider registered in the Lithuanian Commercial Register.
• Keeping records of High Risk clients and reporting suspicious activities to the authorities.
• Report to the Financial Intelligence Unit (FCIS) in case of suspicion of money laundering or terrorist financing.
• Develop and maintain a risk assessment system for products and services, customers and customers, as well as other issues related to money laundering.
• Monitoring and implementation of a permanent AML training program for other employees of a cryptocurrency company.
• Briefing and reporting to senior management on AML internal policies and procedures.
• Organization and conduct of inspections and audits from external organizations, and development of compliance recommendations.

KYC/AML officer applies due diligence measures:

• When establishing a business relationship with a new client
• When a cash payment of more than EUR 15,000 or equal amount in other currency is made
• When verifying information in case of doubt about the authenticity of the documents or data provided
• Suspected of money laundering or terrorist financing

In case of suspicious transactions, KYC/AML officer of a Lithuanian cryptocurrency company should report to FCIS suspicious money transactions or transactions:

• Immediately after receiving information that the customer intends or will attempt to make a suspicious monetary transaction or transaction.
• When it is determined that their client is engaged in a suspicious monetary transaction or transaction, they must suspend the transaction or transaction regardless of the amount of the monetary transaction or transaction and not later than 3 business hours from the moment of suspension of the monetary transaction or transaction to report this transaction or transaction to the FCIS.
• Immediately, within 1 business day of the appearance of such information or suspicion, report to the FCIS if there is a suspicion that the property is directly or indirectly derived from criminal activity.

STR/CTR reports should be sent through the electronic government gateway at login via the website.

Access to the platform requires FCIS permission and Lithuanian ID/ID code.

STRs/CTRs should be submitted in Lithuanian language.

MISSION OF AML OFFICER

The compliance specialist is responsible for implementing the prescribed standards at the institutional level. The professional attention of the specialist is directed to the internal control systems and tools that the institution applies to detect, monitor and report to the authorities on money laundering activities. The main task of KYC/AML officer is to ensure that a particular organization is not exposed to criminal risk and inadvertently does not contribute to financial crimes.

A documented and effectively implemented AML/CFT compliance framework is an essential component of an application for CASP authorisation under MiCA. Applicants must also demonstrate compliance with the applicable requirements concerning governance, management suitability, prudential safeguards, ICT systems, operational resilience, business continuity and client protection. Lithuania does not operate a separate simplified national crypto licence that can be obtained solely by appointing an AML officer or preparing KYC procedures. The following documents should be included in the KYC/AML procedures:

• Customer identification (document requirements, sources of income, proof of residence).
• Means of checking documents provided by clients.
• Authentication of documents of individuals.
• Requirements for storage of documents provided by customers.

ASSIGNMENT OF AML SPECIALIST

AML compliance is an evolving field, so your compliance specialist’s experience should reflect the current regulatory framework. Given the importance of the AML program, the compliance specialist should have all the necessary knowledge and skills in the areas of financial policy and KYC/AML procedures, as well as in the methodologies of financial irregularities. When appointing, it is important that management select a candidate who not only has the ability and experience to perform his or her duties effectively, but also meets the unique professional requirements of his or her institution.

The compliance specialist not only monitors 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 or her duties. The AML/CFT compliance function should be performed by a suitably qualified individual with sufficient authority, independence, access to relevant information and resources to discharge the assigned responsibilities effectively. The institution’s management retains ultimate responsibility for AML/CFT compliance. Combining the AML compliance function with the CEO position is not a universal requirement and may create conflicts of interest or impair independent oversight. The appropriate governance structure must be assessed according to the institution’s size, complexity, risk profile and regulatory requirements.

CANDIDATE REQUIREMENT

• The Board appoints a person who acts as the contact person of the regulatory body (hereinafter – an AML officer). The AML officer is directly responsible to the board of directors and has authority, facilities and access to the necessary information in all structural divisions of the crypto company;
• In this capacity, only a person with the appropriate education, professional abilities, experience, appropriate personal qualities and impeccable reputation, which are required to perform AML duties, can be appointed;
• The appointment of designated AML/CFT responsible persons must comply with the applicable Lithuanian legislation, including requirements concerning professional competence, reputation, authority and availability. Under Article 22 of the Lithuanian AML Law, the appointment or replacement of the relevant responsible persons must generally be notified to FNTT within seven working days. This notification obligation must not be confused with a universal requirement to obtain FNTT’s prior approval for every AML officer appointment. Separate suitability assessments or supervisory requirements may apply depending on the institution’s licence and the individual’s responsibilities.

Company in Lithuania UAB offers the services of an experienced KYC/AML officer (citizen of Lithuania) with knowledge of all the necessary requirements of the regulator and the laws of Lithuania for identification of clients of your cryptocurrency project.