Lithuania — Europe's #1 EMI Hub
Since the Bank of Lithuania launched its fintech-friendly licensing framework in 2016, Lithuania has become the dominant European jurisdiction for EMI licensing. The Bank of Lithuania (Lietuvos bankas) has issued over 100 EMI licences — more than any other EU regulator. Companies including Revolut, Paysera, ConnectPay, and dozens of crypto-native payment firms have chosen Lithuania as their EU payment services base.
The Bank of Lithuania's success as a fintech hub is not accidental. The regulator actively pursues fintech as a strategic priority, maintaining a dedicated fintech team, offering pre-application consultations through its VILN programme, and publishing detailed guidance on EMI application requirements in both Lithuanian and English. The streamlined approach means applicants receive formal feedback within defined timeframes rather than waiting indefinitely.
Lithuania's advantages extend beyond the regulatory process. The country offers one of the lowest corporate tax rates in the EU at 15% (with a reduced 5% rate for startups meeting certain conditions). Vilnius has developed a deep talent pool of compliance officers, AML specialists, and legal advisors with specific EMI licensing experience. Major EU correspondent banks have established relationships with Lithuanian payment institutions, simplifying the safeguarding account process.
For crypto companies specifically, Lithuania combines EMI licensing with a straightforward Virtual Asset Service Provider (VASP) registration process. The Financial Crime Investigation Service (FNTT) handles VASP registrations, and the combined EMI + VASP structure enables crypto payment processors, stablecoin-adjacent businesses, and crypto neobanks to operate under a single Lithuanian entity with full EU passporting.
Bank of Lithuania EMI Requirements
AML 5th Directive Compliance Requirements
Lithuanian EMIs operate under the EU's 5th Anti-Money Laundering Directive (5AMLD, 2018/843/EU) as implemented in Lithuanian national law. The Bank of Lithuania and the Financial Crime Investigation Service (FNTT) jointly supervise AML/CFT compliance for payment institutions. The FNTT has specific oversight of crypto-related activities and maintains direct communication channels with Europol and FATF.
EMI applicants must submit a complete AML/CFT Policy as part of their licence application. The policy must address: customer due diligence procedures (standard, simplified, and enhanced), transaction monitoring methodology, suspicious transaction reporting procedures, correspondent relationship policies, PEP (Politically Exposed Person) screening, and sanctions compliance (EU consolidated list, OFAC, UN).
For crypto-related businesses, the Bank of Lithuania's AML expectations are more detailed. The regulator requires explicit policies for blockchain analytics, crypto address screening, and treatment of high-risk transaction patterns (mixing, tumbling, privacy coins). Companies planning to handle crypto flows must demonstrate that their transaction monitoring systems can handle blockchain data — typically requiring integration with providers like Chainalysis, Elliptic, or CipherTrace.
- AML/CFT Policy covering all business activities and customer types
- Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures
- Transaction monitoring system with defined alert thresholds
- Suspicious Transaction Report (STR) procedures to FNTT
- PEP screening and sanctions compliance programme
- For crypto: blockchain analytics integration and crypto-specific risk assessment
- Annual AML risk assessment and policy review
Step-by-Step Licensing Process
Lithuania EMI Licence Cost Breakdown
| Item | Details | Cost |
|---|---|---|
| Regulatory Capital | Minimum paid-up share capital — held in company | €350,000 |
| Government Application Fee | Bank of Lithuania EMI application fee | ~€1,800 |
| Company Incorporation | UAB setup, notary, Centre of Registers | €2,000–€4,000 |
| Legal & Compliance Preparation | Application documents, AML policy, business plan | €20,000–€50,000 |
| Local Director Fees (Year 1) | Lithuanian-resident director services | €8,000–€20,000 |
| AML/Compliance Officer (Year 1) | Local MLRO appointment and services | €15,000–€35,000 |
| Office Costs (Year 1) | Registered office, operational space | €5,000–€15,000 |
| Banking Setup | Safeguarding account, corporate account opening | €2,000–€5,000 |
| Total Year 1 (excl. capital) | Professional fees and operational setup | €53,000–€130,000 |
| Total Year 1 (incl. capital) | Full investment including regulatory capital | €403,000–€480,000 |
Note on regulatory capital: The €350,000 capital remains in the company as working capital — it is not a fee paid to the regulator. It can be used for operational costs once the licence is active. You do not "lose" this capital; it is equity in your licensed entity.