ROLE OF COMPLIANCE OFFICER
The compliance officer is responsible for implementing regulations at the institutional level. The specialist’s attention is focused on the internal systems and controls that the company uses to detect, monitor, and report money laundering activities to the authorities. The main task is to ensure that the organization is not at risk and does not contribute to financial crimes.
DESIGNATION OF COMPLIANCE OFFICER IN LITHUANIA
Based on the Article 22 Part 1 of the Law on the Prevention of Money Laundering and Terrorist Financing the financial institutions and other obliged entities must designate senior employees for organizing the implementation of money laundering and/or terrorist financing prevention measures specified in this Law and for liaising with the Financial Crime Investigation Service (FNTT). Where the financial institutions or other obliged entities are led by the board, the financial institutions and other obliged entities must designate a member of the board for organizing the implementation of money laundering and/or terrorist financing prevention measures specified in this Law and senior employees for liaising with the Financial Crime Investigation Service. The Financial Crime Investigation Service must be notified in writing of the designation as well as replacement of such employees and board members not later than within seven working days from the date of their designation or replacement.
Information must be provided by the notification written by email dokumentas@fntt.lt Please note that email and telephone number must be included into the letter.
Moreover, virtual currency exchange operator and depository virtual currency wallet operator, or the beneficiary of such entities may not be a natural person who has been convicted of a serious crime against property, property rights and property interests, the economic and business order, the financial system, the civil service, and the public interest, and has the criminal record that is in force and has not been annulled.
The requirements for the implementation of AMTF prevention measures are set out in the Prevention of Money Laundering and Terrorist Financing Law of Lithuanian Republic.
Instructions addressed to money operators of deposit virtual currencies and operators of virtual currency exchange offices (Crypto) is described in 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 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.
RESPONSIBILITIES OF THE COMPLIANCE OFFICER
- Development, implementation, and maintenance of an anti-money laundering program of the respective institution.
- Collection and analysis of information on suspicious transactions and reporting to the FCIS in case of suspicion of money laundering or terrorist financing.
- Preparation and submission of written statements on compliance with the requirements of the law to the company’s management.
- Maintenance of High-Risk customer records and reporting to authorities.
- Maintenance of a risk assessment system for products and service and customers, as well as for other issues related.
KYC/AML Officer takes due diligence measures:
- When establishing business relations with a new client.
- Before establishing a business relationship, regardless of transaction value, and in other cases requiring customer due diligence under Lithuanian AML/CFT law and applicable crypto-asset transfer rules. Suspected money laundering or terrorist financing triggers due diligence obligations regardless of any monetary threshold.
- When verifying data in case of doubts about the reliability of submitted documents or data. In case of suspected money laundering or terrorist financing.
DAŽNAI UŽDUODAMI KLAUSIMAI
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To which position should the Compliance officer be assigned?The Compliance Officer is an employee of the company or is a part of the governing body, that is, the Director of the company, duties of the AML Officer are performed by an employee based on the employment agreement. The Finansinių nusikaltimų tyrimo tarnyba (FNTT) must be notified in writing of the appointment or replacement of the responsible senior employees and board members within seven working days. Separate notification and suitability assessment requirements of the Bank of Lithuania must also be observed where applicable.
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Which unit is responsible for reviewing the work of Compliance Officer?The contact person of a company is directly subordinate to the Directors of the credit or financial institution and has the competence, resources, and access to relevant information in all structural divisions of the financial institution, necessary to fulfil the duties provided for in this Law. For a Lithuanian-authorised crypto-asset service provider, the AML officer must cooperate with the Bank of Lithuania as the licensing and supervisory authority and with FNTT as Lithuania's financial intelligence unit. Suspicious transaction reports are submitted to FNTT.
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Should the compliance officer be experienced?Yes, it is required to have experience in this area. Only a person, who has the appropriate education, professional suitability, the necessary abilities, personal characteristics, experience, and impeccable reputation necessary to perform the duties, can be appointed as the KYC/AML Officer. The company appoints the AML officer and notifies FNTT as required by law. Notification to FNTT does not constitute approval of the appointment. The applicable Bank of Lithuania requirements for assessing responsible persons must also be fulfilled.
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Is the compliance officer mandatory from the beginning of crypto company’s operations?A crypto-asset service provider must appoint responsible AML/CFT personnel and establish effective compliance controls before commencing regulated activities. Lithuania's transitional VASP regime ended on 31 December 2025. Registration with the Centre of Registers does not authorise the provision of crypto-asset services in 2026. The provider must hold the required MiCA authorisation or qualify to provide the relevant services under Article 60 of MiCA.
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Is it allowed to hire the Compliance Officer outside of Lithuania?Yes, the company is required to appoint a specialist (Compliance Officer), there are no specific law determining nationality or the living address of this specialist.
| Paslauga | Kaina |
|---|---|
| KYC/AML officer service fee | 750 EUR / month |
** (minimum period of service order – 6 months)
