ECOVIS ProventusLaw welcomes you to the newest newsletter on EMI/PI Regulation, which is dedicated to everyone who wants to understand the latest trends and developments in EMI/PI regulation area, get tips from our experts, and deepen their knowledge.
Fjord Bank AB did not comply with the minimum own funds requirement
Following established procedures, Fjord Bank AB applied to the Bank of Lithuania to conclude an administrative agreement. After evaluating that the institution self-reported the violation, acknowledged it, and corrected it, the Bank of Lithuania decided to enter into an administrative agreement and, as a sanction, publicly announced the legal breach.
Our Recommendation:
1. Strengthen Capital Management:
Implement more robust capital planning and monitoring processes to ensure continuous compliance with minimum own funds requirements.
2. Enhance Risk Assessment:
Regularly assess financial risks that could impact capital adequacy and proactively adjust capital buffers accordingly.
3. Improve Internal Controls:
Establish or improve internal controls to detect potential breaches early and prevent recurrence of non-compliance.
4. Maintain Transparent Communication:
Continue the practice of timely and transparent self-reporting of any regulatory breaches or financial irregularities to the Bank of Lithuania.
Disputes over Financial Services: Q1 2025 Review
In the first quarter of 2025, the Bank of Lithuania reviewed 223 disputes between consumers and financial market participants — 34% more than in Q1 of the previous year and 23% more than the previously recorded highest figures. The number of disputes examined also increased by 26% and 5%, respectively.
This growth was mainly driven by a 17% increase in disputes involving insurers and a twofold increase in disputes with other financial market participants.
Disputes by Service Type
Most disputes concerned non-life insurance services — 98 cases, accounting for 44% of all examined disputes. The most common disagreements were related to property insurance (32), compulsory motor third-party liability insurance (23), and casco insurance (23) contracts. Additionally, 82 disputes involved payment services, making up 37% of all cases. Of these, 53 were related to financial fraud and 18 to non-cash transactions.
Amicable Settlements and Implementation of Decisions
During this period, 36 amicable settlements were reached — 12% fewer than in Q1 2024. However, around EUR 130,000 was paid out due to mediation — more than twice the amount paid in the same period last year (about EUR 60,000). One decision was also made on the substance of a dispute, partially satisfying the consumer’s claims. The insurance company implemented the recommended decision.
Reminder: Wind-Down Plan Now Mandatory for EMIs and PIs
As of April 9, 2025, the amended Resolution No. 03-33 of the Bank of Lithuania has come into effect, introducing mandatory wind-down plan requirements for electronic money institutions (EMIs) and payment institutions (PIs).
Under Resolution No. 03-33, institutions must prepare and formally approve a wind-down plan that ensures the orderly termination of e-money issuance and/or payment services. The collegial management body must adopt the plan and include:
- Impact and risk assessments
- Termination procedures and mitigation measures
- Decision-making structure
- Allocation of resources
- Internal and external communication strategies
Our recommendations:
1. Initiate your wind-down planning immediately if not already in place.
2. Review and update internal policies to ensure complete alignment with the Resolution.
3. Adapt operational processes to support effective wind-down execution.
Our law firm provides complete assistance in drafting compliant wind-down plans and reviewing internal documentation to meet the current legal and regulatory expectations of the Bank of Lithuania. More information.
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