Summary of Draft Resolutions by the Bank of Lithuania

The Bank of Lithuania has initiated a public consultation on proposed amendments to two key resolutions:

Resolution No. 03-17 (12 February 2015): “On the Approval of Instructions to Financial Market Participants to Prevent Money Laundering and/or Terrorist Financing”
Resolution No. 03-98 (30 May 2023): “On the Approval of the Instructions to Financial Market Participants on the Implementation of International Sanctions”

Key Proposed Amendments

AML/CFT Instructions:

Update Clause 2 of the AML/CFT Instructions to align with the amended Law on the Prevention of Money Laundering and Terrorist Financing in Lithuania and the European Banking Authority (EBA) Guidelines on customer due diligence.
Extend the scope of AML/CFT measures to cryptocurrency service providers established in Lithuania, as per Regulation (EU) 2023/1114 on cryptocurrency markets.

Sanctions Instructions:

Add exceptions to the application of Sanctions Instructions for entities offering or requesting inclusion of non-asset-linked cryptocurrencies in trading, provided these entities are not engaged in other activities supervised by the Bank of Lithuania.
Require financial market participants to retain supporting documentation for applying international sanctions measures for 8 years.
Ensure compliance with Lithuanian and EU legislation to implement international sanctions properly.
Align specific provisions of the Sanctions Instructions with updates to Regulation (EU) No. 260/2012 concerning instant credit transfers in euros, as amended by Regulation (EU) 2024/886.

These amendments aim to enhance Lithuania’s compliance with EU standards, strengthen AML/CFT frameworks, and ensure robust implementation of international sanctions. Public feedback is encouraged to refine these resolutions further.

Recommendations of ECOVIS ProventusLaw

Revise internal AML/CFT policies to incorporate changes in the Law on the Prevention of Money Laundering and align with the updated EBA Guidelines on customer due diligence.
Implement robust systems to retain sanctions-related documentation for the mandated eight-year period.
Enhance sanctions screening to comply with both Lithuanian and EU standards.