Financial Institutions and Fintech Licensing in the EU
Comprehensive advisory on financial institution licensing, passporting and regulatory compliance across the European Union and beyond.
We audit CENTROlink participants that register addressable BIC holders (ABIC holders) and prepare the independent audit report for the Bank of Lithuania.
From 1 January 2027, a CENTROlink participant can register ABIC holders only if it submits an independent audit report. This CENTROlink ABIC audit covers the participant’s anti-money laundering and counter-terrorist financing (AML/CTF), fraud prevention and sanctions measures in its relationships with ABIC holders.
Our experienced compliance team carries out the audit and works closely with our Banking and Finance and FinTech teams. It also performs our independent AML audits.
The CENTROlink Rules require appropriate and effective legal, technical and organisational measures for relationships with ABIC holders, covering AML/CTF, fraud prevention and international sanctions. The audit assesses these measures as a whole. We review:
The CENTROlink Rules provide for two separate independent audits, and the Bank of Lithuania may request either of them. The ABIC audit covers the participant’s AML/CTF, fraud prevention and sanctions measures in its relationships with ABIC holders.
The payment systems participation audit checks whether a payment or electronic money institution meets the requirements for participating in payment systems: safeguarding of client funds, governance and internal control, and a winding-up plan. The Bank of Lithuania may request it when the institution applies to join CENTROlink or while it participates.
From 1 January 2027, a participant can register ABIC holders if it:
The first two conditions do not apply if the ABIC holder belongs to the participant’s group and both have the same ultimate beneficial owners.
An ABIC holder must be a payment service provider that is not itself a CENTROlink participant. It must be a credit institution, payment institution or electronic money institution licensed in a Single Euro Payments Area (SEPA) country and meet at least one of these conditions:
ABIC holders can use SEPA Credit Transfer (SCT) and SEPA Instant Credit Transfer (SCT Inst). The Bank of Lithuania notifies the participant of its decision within 20 working days after receiving all documents and clarifications.
Until 30 December 2026, existing ABIC holders operate under their agreements with the Bank of Lithuania, which may extend this to 30 June 2027 in individual cases.
For direct and indirect access to SEPA, fees and the documents needed to join, see SEPA connection via CENTROlink.
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