Financial Institutions and Fintech Licensing in the EU
Comprehensive advisory on financial institution licensing, passporting and regulatory compliance across the European Union and beyond.
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DECompliance and Risk Management Support Service
Comprehensive compliance and risk management support for electronic money institutions, payment institutions and other regulated financial entities operating in Lithuania and across the European Union.
Requirements of current and upcoming legal acts, attitude of the Bank of Lithuania communicated via expectation letters, trainings, inspections, and other means once again prove that compliance is a key for successful and forward-thinking businesses. We bring together a team of experts in various areas to ensure your electronic money or payment institution meets regulatory requirements and gaps are detected and corrected in timely manner.
The framework of our service:
- carrying out an overall risk assessment of compliance function, which helps to see the „hottest“ topics at the company requiring an immediate attention,
- preparation and harmonization of the compliance policy and procedure,
- preparation of compliance monitoring plan, based on the outcome of the risk assessment,
- evaluation and support in particular areas of operation, based on compliance monitoring plan,
- quarterly reports to the management on the status of tasks performed regarding the function of compliance support,
- monthly regulatory update highlighting changes in legal requirements, guidelines/recommendations/best practices of the regulator, relevant aspects of recent case law.
The areas we provide compliance support on:
- AML,
- IT Data management and Cyber security, Business continuity plan,
- Governance, internal control and risk management,
- Conflict of interests,
- Outsourcing,
- Safeguarding of clients’ funds,
- Data protection,
- Terms and Conditions,
- Complaint handling,
- Capital adequacy,
- New product development, compliance to the license,
- Anti-Bribery and Corruptions, Whistleblowing,
- Reporting,
- Employment relationships,
- Occupational safety and health.
Risk management support service
According to the Resolution No. 03-106 of the Bank of Lithuania, electronic money and payment institutions should have approved risk strategy, assign a person who is responsible for risk management, who should present to the management body quarterly risk map and annual risk report. Risk map is a list of all companies existing and potential risks, risk evaluation, risk mitigation measures, responsible person in the company and defined acceptable risk level (limits).
The framework of our service:
- Creation of the risk management framework,
- Preparation of the risk strategy, including risk tolerance limits setting,
- Preparation of the risk policy, covering risk methodology,
- Template for quarterly risk reporting,
- Regular workshops on risk identification with representatives of the company,
- Follow-up of action plans for risk mitigation,
- Internal risk communication plan,
- Support on integration of the risk management into the internal control system,
- Framework for outsourcing risk management (in line with resolution of the BoL No 03-166);
- Template for operational risk register,
- Preparation of the annual risk report.
We offer:
- Professional services from experienced risk managers
- Personal attention
- Regular interactions
- Support
Recent compliance and risk management practice
Trek Labs Ltd. (BVI)
Advised a global fintech group on a qualifying holding review by Latvijas Banka, requiring full transparency of a multi-layered ownership structure spanning VC funds, private investment vehicles, and individual founders across multiple jurisdictions including BVI, Delaware, Cayman Islands, UAE, and Asia-Pacific. The engagement involved preparing a comprehensive regulatory submission covering source of funds, SAFE instruments, Series A financing, beneficial ownership mapping, AML/CTF assessment, and governance analysis — translating a complex cross-border capital structure into an ECB-compliant supervisory framework.
Travel Union
Advised a regulated financial institution on establishing an outsourced compliance governance framework, providing ongoing AML/CTF, safeguarding, data protection, sanctions, and enterprise risk management coverage. The model operates through periodic risk assessment cycles, quarterly monitoring, and structured reporting lines aligned with Bank of Lithuania supervisory expectations.
Holvi Payment Services Oy
Advised a FIN-FSA–authorised payment institution and Mastercard Principal member on a multi-layer regulatory assurance review covering safeguarding architecture, governance and internal controls, and ICT/GDPR operational resilience — integrated into a single cross-disciplinary framework ahead of ongoing EEA supervisory scrutiny.
FINCI
Conducted an independent post-inspection remediation review for a Bank of Lithuania–licensed EMI, assessing whether corrective measures across governance, AML/CTF, sanctions compliance, CDD, transaction monitoring, and internal controls had been effectively implemented and were sustainable under ongoing supervisory scrutiny — including file reviews, system assessments, and senior management interviews.
Ebury Partners Lithuania
Advising a Bank of Lithuania–licensed payment institution on ongoing regulatory governance, including safeguarding framework review, internal controls, product governance, and coordination with group-level audit and compliance functions across a cross-border fintech structure.
AML/CTF remediation for a regulated payment institution (confidential client)
Advised on full-scale AML/CTF remediation following significant Bank of Lithuania supervisory findings, including reconstruction of transaction monitoring architecture, risk scenario design, fraud detection, governance and escalation structures, and second- and third-line control functions — incorporating enhanced crypto-related risk typologies under strict supervisory timelines.
DORA implementation for a hybrid telecoms-financial group (confidential client)
Advised a telecommunications group holding an EMI licence on DORA implementation across a hybrid corporate structure combining telecoms and regulated financial services. The engagement included regulatory scoping to determine proportional DORA application, direct supervisory engagement to clarify interpretative expectations, and full redesign of ICT risk governance, incident reporting, and outsourcing controls — reconciling telecom-scale ICT infrastructure with financial services regulatory accountability.
Our presentation on compliance support services (click the below picture)
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| 2023 | 2024 | 2025 / 2026 |
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