Welcome to our monthly newsletter on Anti-Money Laundering and Counter-Terrorist Financing. It is dedicated to everyone who wants to understand the latest trends and developments, get tips from our experts and deepen their knowledge.
Supreme Administrative Court of Lithuania confirms the per-violation AML fines approach
The Supreme Administrative Court of Lithuania upheld the Bank of Lithuania’s practice of imposing penalties for each individual systematic AML/CTF violation, confirming that it is lawful, proportionate, and aligned with EU law, following guidance from the Court of Justice of the European Union.
The case concerned a €370,000 fine for eight violations, which LVAT ultimately reinstated in full, confirming that sanctions may be assessed separately where breaches are serious and systematic.
Key takeaway:This ruling is of major practical significance. Institutions should not assume that multiple AML/CTF breaches identified in a single inspection will be treated as one consolidated infringement – each systematic violation may attract a separate penalty, substantially increasing overall exposure. The Bank of Lithuania’s approach has now been validated at both the EU and national supreme court levels.
Institutions are strongly advised to review their AML/CTF frameworks holistically, ensuring that monitoring, investigation and STR reporting processes are robust, well-resourced and properly documented.
Bank of Lithuania revokes PAYTEND EUROPE e-money licence
The Bank of Lithuania revoked UAB “PAYTEND EUROPE”’s licence due to serious and systematic AML/CTF violations.
Key deficiencies included:
- ineffective client and transaction monitoring (missed suspicious activity, inadequate alert handling);
- formal/incomplete internal investigations and failure to submit STRs to the Financial Crime Investigation Service;
- weak internal controls, lack of function separation and insufficient AML resources;
- provision of false information to the regulator and failure to retain relevant records;
- failure to submit audited financial statements and supervisory reports on time.
The institution was prohibited from providing financial services as of 4 March 2026 and required to notify clients within 5 business days.
This case represents the most severe supervisory outcome available. It demonstrates that cumulative failures across AML/CTF monitoring, internal governance, STR reporting, the provision of accurate information to the regulator, and the timely submission of financial statements will result in licence revocation. All licensed payment and e-money institutions should treat this case as a benchmark and conduct a thorough review of their AML/CTF frameworks, internal audit processes and regulatory reporting obligations.
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