RegRally Insights: Crypto & Investments Regulation, November 2026

Crypto and investment firms have little time left to update products, client agreements and controls. Investment firms face new settlement requirements in less than a month. Crypto-asset service providers (CASPs) have two months to resolve existing exposures to stablecoins that do not comply with the Markets in Crypto-Assets Regulation (MiCA), while client fund arrangements already need to meet safeguarding requirements.

These changes require decisions now: which tokens to stop supporting, where client money must be held, and which client terms and processes need updating.

One more development not to miss: Latvia licensed two more CASPs in October, in line with Latvia’s government-approved Fintech Strategy and its commitment to increase the number of fintech companies by one third, create new jobs in the sector, attract investment, and establish Latvia as a competitive European fintech hub.

ESMA’s expectations for services involving non-compliant stablecoins

Date: October 8, 2026 | Source: European Securities and Markets Authority (ESMA)
Link

The European Securities and Markets Authority (ESMA) published an Opinion on October 8, 2026 on crypto-asset services relating to asset-referenced tokens (ARTs) and e-money tokens (EMTs) that do not meet the MiCA conditions for a lawful offer to the public or admission to trading. The Opinion is addressed to national competent authorities and sets out how they should supervise CASPs.

ESMA considers that CASPs should not provide any crypto-asset service in relation to non-MiCA-compliant ARTs or EMTs. Providing such services is presumed to be incompatible with the duty in Article 66(1) of MiCA to act honestly, fairly and professionally in the best interests of clients, whether or not the service itself is an offer to the public or an admission to trading. Warnings, disclosures or client acknowledgments do not cure the problem.

The expectation covers all services, individually or in combination: trading platforms, exchange, execution, reception and transmission of orders, placing, advice, transfers, custody and portfolio management. CASPs should not maintain, introduce or facilitate access to such tokens for EU clients and should have technical, contractual and organizational controls that prevent clients from acquiring or increasing positions. Where legacy exposures remain, authorities should require remediation as soon as possible and no later than three months after publication. Until then, only sell-only, conversion, transfer or withdrawal functions may continue, on a time-limited basis and with clear client communication.

Why it matters

The three-month period runs from October 8, 2026, so by January 8, 2027 CASPs should have stopped all services in such tokens for EU clients except an orderly wind-down. Supervisors are asked to check every authorized CASP against this expectation.

Recommended actions

CASPs should:

• identify the ARTs and EMTs on their platforms whose issuers do not meet the MiCA Title III or Title IV conditions;
• block new acquisitions and position increases for EU clients and limit remaining functions to sell-only, conversion, transfer or withdrawal;
• inform affected clients and document a wind-down plan to be completed by January 8, 2027;
• build a token admission control that checks MiCA compliance before any ART or EMT is listed or supported.

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ESMA clarifies client fund safeguarding and crowdfunding access fees

Date: October 16, 2026 | Source: European Securities and Markets Authority (ESMA)
Link (Q&A 2949) | Link (Q&A 2950)

On October 16, 2026, ESMA published new answers to questions under MiCA and the European Crowdfunding Service Providers Regulation (ECSPR).

MiCA Q&A 2949 (answer dated October 6, 2026). A CASP may temporarily hold client funds in a payment account with an electronic money institution (EMI) or payment institution (PI), provided it keeps meeting the safeguarding duties in Article 70(2) of MiCA. By the end of the business day following receipt at the latest, it must place the funds with a credit institution or a central bank under Article 70(3). The account must be opened directly in the CASP’s name or under the applicable legal segregation arrangement. An account held in the name of a non-bank payment service provider does not qualify, even if it is set up specifically for the CASP and technically segregated.

ECSPR Q&A 2950. Crowdfunding platforms may charge registration, membership or access fees and still be publicly accessible. However, access conditions must be transparent, objective and non-discriminatory, and investors must receive clear information free of charge before paying, including on the fees and the offers available. For non-sophisticated investors, the investor categorization, entry knowledge test, loss-bearing simulation and risk warnings should be completed before any fee is paid. Commercial relationships with finfluencers promoting fee-based access must be disclosed.

Why it matters

Where a CASP receives client money through an EMI or PI account, including an account the provider opened specifically for the CASP, ESMA’s answer means that account may serve only as a transit point until the end of the next business day.

Recommended actions

CASPs and crowdfunding service providers should:

• map where client funds are held and move them to an account with a credit institution or central bank, opened directly in the CASP’s name or under the applicable legal asset segregation arrangement, by the end of the next business day;
• update safeguarding policies, reconciliation procedures and contracts with payment service providers;
• for crowdfunding platforms with access fees, re-sequence onboarding so that categorization, testing and warnings come before payment, and update fee disclosures.

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Latvijas Banka continues to issue MiCA licenses

Date: October 1, 2026 | Source: Latvijas Banka
Link (Atrya Technologies) | Link (Noah LV)

Latvijas Banka announced two new crypto licensing decisions on October 1, 2026. Atrya Technologies SIA received a CASP license for the custody and administration of crypto-assets on behalf of clients and for the exchange of crypto-assets for other crypto-assets. Noah LV SIA received a CASP license covering custody and administration, exchange of crypto-assets for funds, execution of client orders and crypto-asset transfer services, and at the same time a payment institution license for payment transactions, credit transfers and standing orders. Both licenses are valid across the EU under the cross-border notification mechanism.

Noah LV obtained the two licenses in separate procedures, but both were granted on the same day, as is now common in Latvia, so the company can offer crypto and payment services side by side from the start. Latvia has now licensed 12 CASPs under MiCA and has 13 licensed payment institutions.

Why it matters

Interest from crypto-asset businesses in Latvia keeps growing, and we are receiving inquiries about MiCA licensing in Latvia. For business models that combine crypto and payment services, the Noah LV decisions show how the Latvian route works in practice: two separate procedures, coordinated so that both licenses arrive at once.

Recommended actions

Crypto-asset businesses planning EU market entry should:

• consider Latvia when choosing the jurisdiction for a MiCA application;
• for combined crypto and payment models, plan the CASP and payment institution applications in parallel from the start;
• use Latvijas Banka’s pre-licensing consultations before filing the application.

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T+1 preparation: new client requirements from December 7, 2026

Date: October 14, 2026 | Source: Commission Delegated Regulation (EU) 2026/1536 of July 6, 2026 amending the regulatory technical standards on settlement discipline
Link

Commission Delegated Regulation (EU) 2026/1536 amends the regulatory technical standards on settlement discipline in Delegated Regulation (EU) 2018/1229 to prepare for the move of EU securities settlement to T+1 (settlement one business day after the trade). Under Regulation (EU) 2025/2075, from October 11, 2027 transactions in transferable securities executed on trading venues must settle no later than the first business day after the trade. Delegated Regulation (EU) 2026/1536 was published in the Official Journal on October 14, 2026 and entered into force on November 3, 2026. It applies in three steps: December 7, 2026, July 1, 2027 and October 11, 2027.

From December 7, 2026:

• Electronic allocations and confirmations. Professional clients must send written allocations and confirmations in a structured, machine-readable electronic format using international open communication standards, so that they reach the investment firm by 23:00 Central European Time (CET) on the trade date. Unstructured methods are allowed only during documented temporary technical outages. Allocations must include the cash settlement amount, the identifiers of the delivering and receiving participants and the place of settlement, and must apply the cash tolerance levels set by the relevant central securities depository (CSD).
• Two-hour acknowledgment. Investment firms must confirm receipt within two hours, or within one hour after the start of the next business day if they receive the documents less than an hour before close of business.
• Reference data. Investment firms must require professional clients to provide standing settlement data in a structured electronic format and to keep it up to date. Where the firm already has all the information in advance, the parties may agree in writing that allocations and confirmations need not be sent.
• Retail clients. Investment firms must require retail clients to provide all settlement information by 23:00 CET on the trade date, unless the client holds the relevant instruments and cash at the same firm.

Why it matters

The later steps fall mainly on CSDs and their participants: from July 1, 2027 settlement instructions carry the place of trading and participants with high fail rates must report the reasons to their CSD, and from October 11, 2027 instructions should be sent by 23:59 CET on the trade date and CSDs must offer automatic partial settlement. The December 2026 step is the one that changes investment firms’ client relationships, because the regulation makes the firm responsible for requiring its clients to meet the new deadlines and formats.

Recommended actions

Investment firms should:

• amend agreements with professional clients to require electronic allocations and confirmations by 23:00 CET on the trade date and the use of CSD cash tolerances;
• set up the two-hour acknowledgment process and collect standing settlement data electronically;
• update retail client terms for settlement information by 23:00 CET where assets are not held at the firm;
• plan systems testing for the July 2027 and October 2027 steps.

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Lithuania removes spousal authorization requirements for securities sales and fund redemptions

Date: October 23, 2026 | Source: Laws No XV-1224, XV-1225, XV-1226 and XV-1227 of October 15, 2026 amending the Civil Code, the Law on Markets in Financial Instruments and the two laws on collective investment undertakings
Link | Link | Link | Link

On October 15, 2026, the Seimas adopted four laws, published in the Register of Legal Acts (TAR) on October 23, 2026. The substantive amendments take effect on January 1, 2027. The provisions requiring implementing acts under Laws No XV-1225 and XV-1226 took effect on October 24, 2026.

Law No XV-1224 amends Article 3.92(4) of the Civil Code. Until the end of 2026, transactions transferring or encumbering securities that are joint property of spouses may be concluded only by both spouses or by one spouse holding the other’s authorization. From January 1, 2027, this requirement is limited to immovable property and rights in it and to the transfer or encumbrance of a joint enterprise. Securities are no longer listed.

Law No XV-1225 repeals Article 34(4) of the Law on Markets in Financial Instruments, which allowed the spouse’s authorization for transactions in Government savings notes and listed financial instruments to be given in simple written form. The Bank of Lithuania must adopt implementing acts by December 31, 2026.

Laws No XV-1226 and XV-1227 repeal the parallel rules in Article 51(5) of the Law on Collective Investment Undertakings and Article 37(3) of the Law on Collective Investment Undertakings for Informed Investors. Under those rules, one spouse could apply to redeem fund units or shares held in joint ownership only with the other spouse’s authorization. That authorization could be given in simple written form. The Bank of Lithuania must also adopt implementing acts under Law No XV-1226 by December 31, 2026.

Why it matters

Investment firms, banks, management companies and other intermediaries have so far had to collect, check and store spouses’ authorizations before executing sell orders or redemption requests. From January 2027 this step falls away for securities and fund units, while the general Civil Code rules on joint marital property continue to apply.

Recommended actions

Investment firms, management companies and other financial intermediaries should:

• plan the removal of spouse-authorization steps from onboarding, order execution and redemption flows from January 1, 2027;
• update client agreements, forms and internal procedures that refer to the authorization;
• follow the Bank of Lithuania’s implementing acts due by December 31, 2026.

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Latvia introduces investment accounts for children from May 1, 2027

Date: October 1, 2026 | Source: Law of September 17, 2026 amending the Financial Instruments Market Law (Latvia)
Link

On September 17, 2026, the Saeima adopted amendments to the Latvian Financial Instruments Market Law. They were published on October 1, 2026 and entered into force on October 15, 2026. The new Article 130.2 on the coming-of-age investment account (pilngadības ieguldījumu konts) applies from May 1, 2027, and complaints about investment services move from the Consumer Rights Protection Centre to Latvijas Banka from January 1, 2027.

Key rules include:

• The account. A cash account and a linked financial instruments account opened in a minor’s name by a credit institution or investment brokerage firm, regardless of the child’s age, for long-term investment until the child reaches majority. The assets belong to the child.
• Who can give instructions. One parent or other legal representative gives orders and may conclude a portfolio management agreement. Paying in, buying and selling permitted instruments, receiving income and reinvesting do not need the orphan’s court’s permission.
• Permitted investments. Transferable securities admitted to a regulated market or an equivalent venue, simple money market instruments and retail investment funds, including exchange-traded funds (ETFs). Derivatives, contracts for difference, leveraged transactions and any transaction that could create liabilities above the account value are prohibited.
• Orphan’s court permission. Needed for withdrawals and transfers out of the account (other than to another such account of the same child), pledges, gifts and closing the account before majority. The firm may execute such orders only after the permission is received, and the assets may not be used for the parents’ obligations.
• Rights at ages 16 and 18. A 16-year-old may transfer his or her free property into the account or open an ordinary investment account with age-appropriate limits. At 18, the restrictions end.

Why it matters

The law gives Latvian banks and brokers a clear regime for long-term investment products in a child’s name. The safeguards are built into the law, so firms must be able to block prohibited instruments and transfers at account level.

Recommended actions

Credit institutions and investment brokerage firms in Latvia that plan to offer the account should:

• design the product with the permitted instrument list and the leverage ban built into the systems;
• set controls that release withdrawals and transfers only against the orphan’s court’s permission;
• prepare client documents, portfolio management terms and onboarding for legal representatives before May 1, 2027.

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Latvia’s Listing Act changes: research payments and issuer-sponsored research

Date: October 30, 2026 | Source: Law of October 15, 2026 amending the Financial Instruments Market Law (Latvia)
Link

On October 15, 2026, the Saeima adopted amendments to the Latvian Financial Instruments Market Law transposing the Listing Act Directive (EU) 2024/2811, which amends the Markets in Financial Instruments Directive II (MiFID II). They were published on October 30, 2026 and enter into force on November 13, 2026.

Key changes for investment firms include:

• Paying for research. An investment brokerage firm or credit institution that receives research from a third party that also executes its orders may pay for both jointly if it meets the following conditions:
  • It has an agreement specifying how much of the payment relates to research.
  • It tells clients whether it pays jointly or separately and makes its policy on such payments available, including how conflicts of interest are managed.
  • It assesses the quality and usefulness of the research every year.

  Separate payments must come from the firm’s own resources or a research payment account.

• What does not qualify as investment research. Market commentary closely related to order execution is not investment research. For research from independent third parties, the firm records the total costs, where known, and provides this cost information to clients annually on request.
• Issuer-sponsored research. Research paid for wholly or partly by the issuer may be labeled as issuer-sponsored only if it follows the EU code of conduct in Delegated Regulation (EU) 2026/1092, with a clear statement on the first page. Other issuer-paid research must be labeled as a marketing communication. Latvijas Banka may stop the distribution of financial instruments if the issuer-sponsored research does not comply with Delegated Regulation (EU) 2026/1092.
• Listings and SME growth markets. Shares may be admitted to a regulated market only if the admitted share class represents at least 10% of the share capital, excluding strategically held shares and shares held by supervisory and management board members, subject to statutory exceptions notified to Latvijas Banka. Segments of a multilateral trading facility (MTF) may be registered as small and medium-sized enterprise (SME) growth markets. Audit committee rules for listed companies are also relaxed.

Why it matters

The research rules replace strict unbundling with a choice, but the choice must be documented, disclosed to clients and reviewed every year. Research distributed to clients now needs a check on who paid for it.

Recommended actions

Investment brokerage firms and credit institutions providing investment services in Latvia should:

• decide between joint and separate payment for research and update the policy and client disclosures;
• set up the annual assessment of research quality and usefulness;
• check research distributed to clients for issuer sponsorship and label it correctly.

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New derivatives clearing thresholds from November 10, 2026

Date: October 21, 2026 | Source: Commission Delegated Regulation (EU) 2026/2343 of July 14, 2026 amending Delegated Regulation (EU) No 149/2013
Link

Commission Delegated Regulation (EU) 2026/2343 sets the clearing thresholds required by Regulation (EU) 2024/2987 (EMIR 3). Under the amended Articles 4a and 10 of the European Market Infrastructure Regulation (EMIR), every 12 months a financial counterparty may calculate its uncleared positions and its aggregate positions in cleared and uncleared over-the-counter (OTC) derivatives, and a non-financial counterparty its uncleared positions (excluding hedging contracts). EMIR 3 applies these new calculation rules only from the entry into force of the regulatory technical standards under Article 10(4) of EMIR, the provision under which this Delegated Regulation is adopted. It was published in the Official Journal on October 21, 2026 and enters into force on November 10, 2026.

The new thresholds (gross notional value) are:

• Aggregate positions (financial counterparties, asset classes subject to the clearing obligation): EUR 1 billion for OTC credit derivatives and EUR 3 billion for OTC interest rate derivatives.
• Uncleared positions: EUR 0.8 billion for credit, EUR 0.7 billion for equity, EUR 2.2 billion for interest rate and EUR 3 billion for foreign exchange derivatives, and EUR 4 billion combined for commodity and emission allowance derivatives.
• Yearly assessment of clearing thresholds. ESMA must assess at least yearly the prices and volatility of underlyings, clearing rates, inflation, global financial conditions and geopolitical uncertainty, and start a review of the thresholds if they change significantly.

Why it matters

A counterparty that does not calculate its positions is treated in the same way as one that exceeds a threshold. It must immediately notify ESMA and its competent authority. A financial counterparty must also set up clearing arrangements within four months. It must clear contracts in classes subject to the clearing obligation that are entered into or novated after that period. It remains subject to the obligation until it shows the competent authority that its positions are below the thresholds. Financial counterparties calculate positions at group level, while undertakings for collective investment in transferable securities (UCITS) and alternative investment funds (AIFs) calculate them at fund level. Non-financial counterparties calculate their own uncleared positions, excluding qualifying hedging contracts.

Recommended actions

Investment firms and other counterparties trading OTC derivatives should:

• calculate uncleared positions and, for financial counterparties, aggregate positions under the EMIR 3 method and the new thresholds, rather than skip the calculation;
• if a threshold is exceeded, notify ESMA and the competent authority immediately and set up clearing arrangements within four months;
• document the calculation and the result for the competent authority.

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Council agrees key elements of market integration and supervision reforms

Date: October 9, 2026 | Source: Council of the European Union, draft legislation
Link | Link

On October 9, 2026, the Council of the EU reached political agreement on the key elements of its negotiating position on the market integration and supervision package (MISP), on the basis of a Presidency note of October 5, 2026 (ST 13777/26). The package consists of three Commission proposals: a regulation amending the ESMA Regulation and 13 other regulations, including MiCA, EMIR, the Markets in Financial Instruments Regulation (MiFIR) and the CSD Regulation; a directive amending the UCITS Directive, the Alternative Investment Fund Managers Directive (AIFMD) and MiFID II; and a new regulation on settlement finality replacing Directive 98/26/EC.

The texts are not in force. The Council’s compromise text has not been published and its position has not yet been formally adopted. Negotiations with the European Parliament follow once Parliament adopts its own position.

Key elements include:

• Direct ESMA supervision. ESMA would directly supervise significant CASPs, significant trading venues, significant central counterparties (CCPs) and CSDs, as well as pan-European market operators (PEMOs) that opt in. A trading venue would be significant with at least 5% of relevant Union trading activity as part of a group operating venues in at least two Member States, or at least 15% with a sustained cross-border share of at least 85% (shares, ETFs and bonds) or 90% (derivatives). The note does not set out the criteria for significant CASPs. National authorities would keep market abuse surveillance and sanctioning powers.
• ESMA governance. A new full-time, independent Executive Board would take decisions on directly supervised entities, while the Board of Supervisors keeps regulatory decisions, strategy, budget and supervisory convergence. ESMA-led joint transition teams would support the transfer, and a Fees Committee would scrutinize supervisory fees.
• Asset management. Simpler delegation within EU groups, coordination colleges for large cross-border groups, common authorization information requirements and templates, and shorter passporting timelines, with host Member States barred from adding requirements in areas governed by EU law. Member States may allow UCITS and AIFs to appoint a depositary in another Member State.
• Distributed ledger technology (DLT) Pilot Regime. The main threshold would rise to EUR 300 billion (EUR 500 billion possible by delegated act), with a simplified regime up to EUR 10 billion and unbundled services up to EUR 50 billion. CASP trading platforms would become eligible.
• Trading and post-trading. A wider consolidated tape with three levels of order-book data, a framework for frequent batch auctions, tick size adjustments and settlement finality rules moved into a directly applicable regulation.

Why it matters

For fund managers, the cross-border depositary would be optional for Member States, so whether Lithuanian, Latvian or Estonian funds can use it will depend on national choices.

Recommended actions

CASPs, investment firms and fund managers should:

• follow the criteria for significant CASPs in the final text and assess whether their business could move to direct ESMA supervision;
• for fund managers using group delegation or several depositaries, track the asset management changes and the national choice on the depositary passport;
• for firms considering DLT-based market infrastructure, reassess the DLT Pilot Regime once the higher thresholds are agreed.

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Strong stakeholder support for the ECB’s Appia tokenization roadmap

Date: October 28, 2026 | Source: European Central Bank (ECB)
Link

On October 28, 2026, the European Central Bank (ECB) published the Eurosystem report on the public consultation on the Appia Roadmap, the Eurosystem initiative for a European tokenized financial ecosystem with central bank money at its core. The consultation received 127 responses from financial institutions, market infrastructures, technology providers and public authorities. Respondents broadly supported the roadmap’s principles, the role of central bank money as the anchor of tokenized finance, and common standards to avoid market fragmentation.

No design decisions have been taken: the architecture options remain open and will be assessed in the work leading to the Appia blueprint in 2028. Market participants will be invited to join dedicated workstreams on tokenized deposits and payments, tokenized securities, shared network governance and standards. Since September 21, 2026, the Eurosystem has been providing tokenized central bank money through Pontes, and it has accepted DLT-based assets as eligible collateral since March 2026.

Why it matters

Appia is a wholesale infrastructure project and creates no obligations or deadlines for CASPs or investment firms. The direction matters for banks, CSDs and operators of DLT-based market infrastructure, and it complements the DLT Pilot Regime changes in the Council’s MISP position.

Recommended actions

Banks, market infrastructures and firms building DLT-based services should:

• consider joining the Appia workstreams on tokenized deposits and payments, tokenized securities, network governance and standards;
• for DLT-based settlement plans, follow Pontes as the route to tokenized central bank money;
• align tokenization projects with the 2028 Appia blueprint timeline and the DLT Pilot Regime changes under MISP.

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Our view

For CASPs, the stablecoin Opinion is the development of the month. ESMA has turned a question of interpretation into a supervisory expectation with a deadline: by January 8, 2027, services in non-compliant ARTs and EMTs should be wound down for EU clients.

The client funds Q&A takes the same approach. Both texts look at where client assets and client money are actually held, not at how the arrangement is described in the documents. We recommend that CASPs review token listings and client money flows together, since both turn on the same evidence: what clients can access and where their assets are held.

For firms deciding where to seek authorization, Latvia has practical advantages. The Electronic Clearing System (EKS) lets non-bank payment service providers participate directly in SEPA payments. Latvijas Banka’s Instant Verification Service provides real-time payee name verification and is used by financial institutions across Europe. Corporate income tax is 0% on undistributed or reinvested profits. Coordinated AML intelligence-sharing between the Latvian, Lithuanian and Estonian Financial Intelligence Units adds regional risk mitigation.

For investment firms, the T+1 timetable now has a first fixed date. From December 7, 2026, firms must require their professional clients to send electronic allocations and confirmations by 23:00 CET on the trade date. That is a contract change, not only a systems change, and it should go into client documents before December rather than after the first late allocation.

In Lithuania, investment firms and management companies will no longer need the spouse’s authorization for selling securities and redeeming fund units from January 1, 2027. In Latvia, the coming-of-age investment account and the Listing Act rules on research add new products and documentation duties for banks and brokers.

The MISP agreement is worth tracking now, but it is not binding: the Council’s text is not yet public or formally adopted, and Parliament has still to set its position. For CASPs, the question to watch is which of them will count as significant and move to ESMA supervision.

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How ECOVIS ProventusLaw can help

We advise CASPs, investment firms and fund managers from authorization to ongoing supervision.

• MiCA token review: assessing whether supported ARTs and EMTs meet MiCA conditions and preparing wind-down plans.
• Safeguarding of client funds: reviewing client money flows, account structures and safeguarding policies against MiCA Article 70.
• MiCA licensing: CASP authorization and white paper preparation in Lithuania, Latvia and Estonia.
• Parallel licensing in Latvia: pursuing the CASP and payment institution licenses in parallel procedures, so the business has direct access to fiat payments from launch.
• Crowdfunding: reviewing ECSPR onboarding, fee models and investor protection procedures.
• Investment services: updating investment firms’ client documents and procedures following legislative changes, including T+1 allocation and confirmation duties and the spouse authorization change.
• Latvian investment products: structuring coming-of-age investment accounts and research payment policies under the amended Financial Instruments Market Law.
• Anti-money laundering and countering the financing of terrorism (AML/CFT) and sanctions: internal controls, AML/CFT and sanctions compliance for crypto and investment businesses.

Contact our crypto regulatory team to review your stablecoin offering before January 8, 2027.

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Why ECOVIS ProventusLaw

ECOVIS ProventusLaw is one of the most experienced financial regulatory law firms in the Baltics, ranked by IFLR1000, The Legal 500 and Chambers and Partners. We have advised crypto and blockchain businesses since 2014.

Our teams work across Lithuania, Latvia and Estonia, with a lead partner coordinating regulatory and compliance matters and serving as the client’s main point of contact. Through the ECOVIS International network in more than 90 countries, we also support businesses operating across multiple jurisdictions.

We have advised on more than 40 end-to-end licensing projects, from initial business structuring and regulatory applications to ongoing supervision and compliance. Our experience includes the questions supervisors now ask about stablecoins and client funds.

Our regulatory, compliance and audit teams provide legal advice, operational support and independent reviews of anti-money laundering controls and internal procedures. Their work covers licensing, AML/CFT, sanctions, internal controls and regulatory risk management.