Obtain a License for Electronic Money in Lithuania

Other tasks relating to the licensing of e-money institution which may require additional time include

• Preparation of business model and business plan;
• Filling in the management positions (certain qualification and experience requirements are applicable);
• Preparing description of IT system (and other planned technical solutions);
• Preparing the accountancy system description;
• Contracting third parties (e.g. auditing company).

Documents for Licensing of an Electronic Money Institution

• Articles of association;

• A program of operations;

• A business plan, including a forecast budget for the first three financial years which demonstrates that the electronic money institution is able to operate soundly and employs the appropriate internal control systems, procedures and resources;

• The evidence that the minimum size of the equity capital does not fall below the required amount;

• A description of the measures taken for safeguarding electronic money holders’ funds, and where payment services not relating to issuance of electronic money are to be provided, also a description of the measures taken (to be taken) for safeguarding payment service users’ funds;

• A description of the governance arrangements and internal control mechanisms applied, including administrative, risk management and accounting procedures;

• A description of the internal control mechanisms established in order to comply with obligations in relation to prevention of money laundering and terrorist financing;

• A description of the structural organization, including the intended use of branches, agents, natural or legal persons through which the electronic money institution intends to distribute or redeem electronic money or other entities to which activities will be outsourced, and a description of participation in payment systems;

• The data on the identity of persons holding qualifying holdings in the authorized capital and/or voting rights of the electronic money institution, the size of their holdings in the authorized capital and/or voting rights, also evidence of the suitability of these persons taking into account the need to ensure the sound and prudent management of an electronic money institution;

• The identity of directors, including the persons responsible for the management of the electronic money issuance activities of the electronic money institution as well as evidence that they are of good repute and meet the requirements set forth by the legislation;

• Data of an audit firm which performs audit or a certified auditor independently performing audits;

• The address of the registered office.

• Certain other documents, e.g. lease agreement of the premises, are also presented to the Bank of Lithuania when applying for a license. It should also be mentioned that the Directive 2015/2366 on payment services in the internal market (PSD2) (also applicable for e-money institutions) establishes additional requirements in relation to the documents and contents thereof. The requirements prescribed by PSD2 are yet to be transposed to Lithuanian legislation (the term of transposition into national legislation is 13 January 2018), nonetheless, the supervisory authority requires the documents submitted to be in compliance with the PSD2 and relevant guidelines.

• Please note that most of the documents can be submitted in English language, thus, the translation costs are avoided.

Process of Licensing of E-Money in Lithuania

• The signed papers will be considered by the Central Bank of Lithuania no longer than 3 months from the filing date. The decision to issue a license for EMI will be made after consideration of the above documents within the same 3 months.

• In case when there is to be identified any imperfections in the documents regarding the form of the document, as well as in their content, the controlling authority will request for the missing information, or corrected form according to regulatory requirements. In this case, considering period (3 months) is to be counted from the date when the last documents were filed.