KYC/AML Officer in Lithuania

AnastasiaWithin 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.

If the Lithuanian company is a Virtual Currency Exchange Operator or Virtual Currency Depository Wallet Operator, then a KYC/AML officer for such company is required.

Financial Crime Investigation Services of the Republic of Lithuania (FCIS) regulates the activities of companies providing virtual currency exchange services or virtual currency depository purse services in Lithuania

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. The appointment and replacement of such officers and members of the FCIS Board of Directors shall be notified in writing not later than within seven working days from the date of their appointment or replacement.

To add a KYC/AML officer to a Lithuanian cryptocurrency company, you must provide FCIS name, surname, personal code, phone number and email address of that person to the email [email protected]. The nominated person will be informed of further instructions.


  • 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.


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.

KYC/AML procedures are the necessary link to apply for a single crypto license in Lithuania. 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.


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. Ideally, an AML specialist should be a CEO with industry experience to deal with all aspects of their professional environment.


  • 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 an AML officer must be agreed with the regulator. The regulator has the right to obtain information from various sources to verify the applicant’s eligibility.

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.

Assistance in recruiting a KYC/AML officer in Lithuania
2,000 EUR


  • What is the position of KYC/AML officer in the company?
    The compliance specialist is either an employee of the company, or is the structure of the management body, i.e. the board of directors of the company. It is also possible to order this service from a third party company. The duties of an AML officer can be performed by an employee or a structural unit, but only an individual can inform the FCIS of suspicious financial transactions if there is an Lithuanian identification/personal code. If the contact person’s tasks are performed by a business unit, the head of the business unit is responsible for the tasks and should be the contact person.
  • To whom should the compliance specialist answer?
    The financial institution’s contact person shall be directly subordinate to the board of directors of the credit institution or financial institution and shall have competence, resources and access to relevant information in all structural units of the financial institution, necessary to fulfil the obligations stipulated in this Law. Also, the AML officer should cooperate with state departments (in the case of the Lithuanian cryptocurrency company – this is the FCIS) and contribute to the fight against money laundering and reduce the risk of financing terrorism.
  • Is KYC/AML officer experience required?
    Yes, it is desirable to have experience in this field. Only a person who has the appropriate education, professional suitability, necessary abilities, personal characteristics, experience and impeccable reputation necessary for the performance of the duties of a specialist, can be appointed as a KYC/AML officer. The appointment of the KYC/AML officer is coordinated with the FCIS.
  • What happens if the company does not comply with the compliance requirements?
    If the company does not comply with AML requirements, licenses and permits for financial activities can be revoked. If the verification carried out by the FCIS reveals deficiencies, and it becomes apparent that the credibility of the person responsible for the satisfaction is in doubt as a result of his or her omission or the person’s reputation is flawed, the cryptocurrency company may receive prescriptions for defects and be subject to sanctions by the regulator
  • In which case does the organization need a compliance specialist?
    All crypto companies should have a compliance specialist. The board of a financial institution, which is a cryptocurrency company and the head of a branch of a foreign credit institution and a financial institution registered in the Lithuanian commercial register, appoints a person who is the contact person of the company with FCIS. The functions of the contact person include, inter alia:
    • Organization and analysis of information relating to unusual transactions or circumstances suspected of money laundering or financing of terrorism that arise in the activities of an obligatory person;
    • providing information to the FCIS in case of suspicion of money laundering or financing of terrorism;
    • Submission of periodic written reviews of the requirements arising from this Law to the board of the financial institution;
    • fulfilment of other obligations related to compliance with the requirements of the Law
  • What is the connection between the application for a crypto license in Lithuania and the presence of a KYC/AML officer with the applicant company?
    If you wish to apply for a cryptocurrency license in Lithuania, your company will need the presence of a KYC/AML officer.
  • How to find a suitable KYC/AML officer for the company?
    Company in Lithuania UAB offers the services of an experienced KYC/AML officer (citizen of Lithuania) with knowledge of all relevant requirements and laws of Lithuania for your cryptocurrency project.