Lithuania Crypto Exchange License with Incluence Expert Support

The country stands out because of its regulatory clarity. Unlike some EU member states that impose heavy barriers to entry, Lithuania offers a clear legal framework for crypto businesses while remaining aligned with EU Anti-Money Laundering (AML) directives and upcoming Markets in Crypto-Assets Regulation (MiCA).

Additional advantages include:

• EU single market access for licensed companies
• Fast-track licensing process compared to other EU countries
• Availability of skilled professionals in compliance, IT, and finance
• Positive reputation among regulators and investors

As a result, Lithuania has become a preferred jurisdiction for crypto exchanges, wallet operators, and blockchain startups seeking regulatory certainty and operational flexibility within the EU.

A crypto exchange license in Lithuania grants companies the legal status to provide a wide range of Virtual Asset Service Provider (VASP) activities under the supervision of Lithuanian regulators. This license is highly valued within the European Union, particularly as Lithuania is positioning itself as one of the leading crypto-friendly jurisdictions in the region ahead of the full application of the EU-wide Markets in Crypto-Assets Regulation (MiCA) in December 2024–2025.

Licensed activities include:

• Fiat-to-Crypto Exchange – enabling users to buy and sell digital assets against fiat currencies (e.g., EUR ↔ BTC, USD ↔ ETH).
• Crypto-to-Crypto Exchange – facilitating transactions between cryptocurrencies and stablecoins (e.g., BTC ↔ ETH, USDT ↔ BNB).
• Custodial Wallet Services – offering digital wallets with the ability to safeguard private keys and securely store client assets.
• Transaction Mediation – acting as an intermediary for crypto trades, providing liquidity solutions, and operating exchange platforms.

Key Regulatory Bodies and Legal Framework

Two main institutions oversee crypto activities in Lithuania:

1. Financial Crimes Investigation Service (FCIS) – the primary authority for supervising Virtual Asset Service Providers (VASPs). FCIS ensures compliance with AML and Counter-Terrorist Financing (CTF) requirements.

2. Bank of Lithuania – although not directly regulating VASPs, it plays a key role in shaping financial market policies, payment systems, and the integration of crypto with traditional financial services.

The main legal framework is based on:

• Lithuanian AML Law, implementing the EU's 5th and 6th AML Directives
• EU MiCA Regulation, which will harmonize licensing across Europe starting in 2024–2025
• National tax and corporate laws, applicable to all Lithuanian companies

Lithuania has become one of the most attractive EU jurisdictions for cryptocurrency service providers by offering a clear and flexible licensing framework. At present, two types of licenses are available under Lithuanian law, both of which fall under the Virtual Asset Service Provider (VASP) regime:

1. Virtual Currency Exchange Operator License

This license authorizes a company to:

• Exchange virtual currencies to fiat
• Exchange crypto-to-crypto pairs
• Facilitate peer-to-peer trading through an exchange platform
• Act as an intermediary in transactions between counterparties

Business models covered:

• Centralized exchanges (CEX)
• OTC (Over-the-Counter) crypto trading desks
• Crypto brokers and liquidity providers
• Payment gateways enabling crypto-fiat conversions

This license is the cornerstone for companies looking to build crypto trading platforms or integrate exchange functionalities into fintech and payment systems.

2. Depository Wallet Operator License

This license permits businesses to:

• Offer custodial wallets for storing digital assets
• Manage clients' cryptographic keys securely
• Ensure safekeeping and recovery of assets in case of technical failure or security breach
• Provide transaction initiation services on behalf of clients

Business models covered:

• Crypto custodians and wallet providers
• Exchanges offering wallet infrastructure alongside trading
• Neobanks and fintech apps integrating custodial crypto solutions
• Institutional custody services for funds, family offices, and asset managers

With the growing demand for institutional-grade custody and compliance with AML/KYC standards, this license is critical for businesses aiming to build trust and long-term client relationships.

3. Obtaining Both Licenses: A Comprehensive Crypto Exchange

Many companies choose to obtain both licenses simultaneously. Doing so allows them to operate as a fully authorized crypto exchange in Lithuania, covering the entire ecosystem of services:

• Fiat ↔ Crypto conversion
• Crypto ↔ Crypto trading
• Custodial wallet services
• Transaction intermediation and liquidity provision

This combined licensing structure enables businesses to position themselves as one-stop platforms, which is increasingly important as competition in the EU crypto market intensifies under MiCA.

4. Lithuania vs. MiCA: Future-Proof Licensing

While MiCA will harmonize crypto regulation across the EU by 2025–2026, Lithuania's dual-license model already closely aligns with MiCA's definition of VASPs, making it a future-proof solution.

• The Exchange Operator License corresponds to MiCA's definition of crypto-asset service providers (CASPs) offering exchange and trading services.
• The Depository Wallet License corresponds to custody and administration of crypto-assets on behalf of clients under MiCA.

Companies that secure both licenses in Lithuania now will be well-prepared to transition smoothly into MiCA-compliant CASP authorization, benefiting from Lithuania's fast licensing process and regulator experience.

For most international crypto startups, it is strategically advantageous to apply for both licenses at once. This not only future-proofs operations but also increases trust with banking partners, institutional investors, and regulators across the EU.

Lithuania has positioned itself as a leading EU hub for Virtual Asset Service Providers (VASPs), but licensing is subject to strict compliance requirements designed to ensure only transparent and financially sound operators are admitted to the market. These requirements are closely aligned with the upcoming Markets in Crypto-Assets (MiCA) Regulation, meaning companies licensed today in Lithuania are better positioned for future EU-wide operations.

1. Minimum Share Capital

• Exchange Operators (VASP / CASP under MiCA): A minimum of EUR 125,000 is required. This reflects EU harmonization under MiCA, where higher capital thresholds are intended to safeguard clients and reduce systemic risks.
• Wallet (Custody) Operators: Historically lower (EUR 50,000–75,000), but under MiCA, these thresholds are expected to increase as well.

Strategic Note: While incorporation of a Lithuanian UAB requires just EUR 2,500, this does not substitute the minimum regulatory capital. Businesses should budget realistically for paid-up share capital in line with MiCA's future framework.

2. AML/KYC Policies

Lithuania follows EU's 5th and 6th AML Directives and has enhanced monitoring standards. Applicants must prepare comprehensive AML/CFT procedures, including:

• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for high-risk clients
• Transaction monitoring systems capable of detecting suspicious activity in real time
• Sanctions screening against EU and UN lists
• Ongoing monitoring & reporting obligations to the Financial Crime Investigation Service (FCIS)

Regulators now expect not only written AML policies, but also proof of technical implementation — meaning applicants should be ready to present actual KYC/AML software solutions integrated into their operations.

3. Resident AML Officer (MLRO)

A local AML/CTF Officer must be appointed (the so-called MLRO). Their responsibilities include:

• Acting as the primary point of contact with the FCIS
• Preparing and submitting Suspicious Activity Reports (SARs)
• Overseeing internal training and compliance monitoring

Many applications fail because companies appoint "nominal" AML officers without real expertise. Lithuanian regulators increasingly check the experience, certifications (e.g., ACAMS), and employment contracts of MLROs.

4. Registered Office in Lithuania

• A registered physical or virtual office in Lithuania is mandatory
• For licensing purposes, a virtual office is sufficient, but regulators increasingly prefer applicants that can demonstrate substance (employees, AML officer, IT infrastructure in Lithuania)
• Under MiCA, substance requirements will tighten, meaning applicants should already plan for at least minimal local presence

5. Reputation of Shareholders and Directors

Fit & Proper checks apply to all significant shareholders and executives:

• No criminal record in Lithuania or abroad
• No history of bankruptcy or regulatory sanctions
• Financial capacity to support the company's operations

Regulators conduct cross-border checks through EU cooperation channels. In practice, applicants should prepare apostilled police clearances and bank reference letters for credibility.

6. Business Plan & Risk Management Strategy

Applicants must submit a detailed business plan, including:

• Service portfolio (exchange, custody, brokerage)
• Target markets (EU, global, institutional vs. retail)
• Financial projections (3–5 years)
• Operational model, including IT systems, security, and outsourcing arrangements
• Risk management measures against fraud, hacking, liquidity crises, and compliance breaches

Regulators assess whether the business model is credible and sustainable. Overly "generic" plans risk rejection or lengthy delays. A professional, data-driven business plan significantly strengthens the application.

Obtaining a Lithuanian crypto exchange license involves a structured process, but successful navigation requires careful planning:

1. Company Formation (UAB Incorporation)

• Incorporation of a Private Limited Liability Company (UAB)
• Minimum share capital: EUR 2,500 for incorporation (not the regulatory capital)

2. Corporate Documentation

• Drafting company statutes, shareholder agreements, and director appointments
• Preparation of AML/KYC internal rules and policies

3. AML/KYC Framework Implementation

• Appointing a qualified MLRO
• Demonstrating integration of compliance technology (KYC providers, transaction monitoring)

4. Application Submission

• Filing with the Financial Crime Investigation Service (FCIS) and other competent authorities
• Submission includes all corporate documents, AML policies, MLRO CV, financial plan

5. Regulatory Review & Q&A

• Regulators frequently request clarifications
• Companies must respond professionally and promptly; poor-quality responses often delay approvals

6. Bank Account Opening

• Opening corporate and operational accounts in Lithuania or within the EU

Expert Note: Banking is often the most challenging part — Lithuanian banks are selective, but EMIs (Electronic Money Institutions) and specialized fintech banks across the EU can be viable alternatives.

7. License Approval & Ongoing Compliance

• Once approved, the company is entered into the Lithuanian Register of Legal Entities as a licensed VASP
• Ongoing duties: Regular AML reporting, audits, updating policies, and maintaining local presence

One of Lithuania's strengths is the speed of the licensing process.

Timeline: Typically, 1–3 months from company incorporation to full licensing, provided all documents are prepared correctly.

Costs:

• State fees: relatively low compared to other EU jurisdictions
• Legal services: vary depending on complexity (Incluence offers full packages)
• AML Officer fees: depend on whether outsourced or employed
• Share capital: from EUR 125,000 for exchange operators under MiCA

Choosing Lithuania for your crypto license comes with several advantages:

• EU/EEA Market Access: Operate across the entire EU single market after MiCA passporting
• Regulatory Certainty: Transparent framework, aligned with EU directives
• Investor and Client Trust: A licensed company signals compliance and credibility
• Strong Fintech Ecosystem: Lithuania ranks among Europe's top fintech hubs, providing a collaborative environment for startups

After obtaining a license, crypto businesses must ensure continuous compliance. Obligations include:

• Regular Reporting: Submission of suspicious transaction reports (STRs) to FCIS
• AML/KYC Updates: Ongoing monitoring of customer activity and risk assessment
• Record-Keeping: Maintaining transaction records for at least 8 years
• Annual Audits: Depending on business volume, independent audits may be required
• Policy Updates: Adapting to evolving EU and Lithuanian regulations, especially MiCA

Compliance is not a one-time task but a continuous process, ensuring the business remains reputable, operational, and ready for expansion.

At Incluence, we provide more than just technical assistance — we offer strategic, end-to-end support to ensure your crypto licensing process in Lithuania is seamless, fully compliant, and commercially viable.

Our Core Services Include:

• Legal Consulting. Tailored legal advisory on crypto regulation in Lithuania and the EU, including MiCA impact analysis and business structuring recommendations.

• Company Formation. Full support in incorporating a Lithuanian legal entity, including registered office, corporate governance setup, and local representation.

• Document Preparation. Drafting and adapting a complete set of required documents for submission, including business plans, internal procedures, and ownership structures.

• AML/KYC Policy Development. Development of compliant Anti-Money Laundering and Know Your Customer policies in accordance with Lithuanian law and FATF recommendations.

• AML Officer Provision. Assistance in appointing a qualified local AML Officer (MLRO) — a legal requirement — or provision of outsourced AML officer services.

• Bank Account Assistance. Advisory and facilitation of corporate and operational account opening with EU-based banks and EMI providers.

• Ongoing Compliance Support. Post-licensing support including reporting obligations, internal audits, employee training, and regulatory updates.

Contact our licensing team today to receive a tailored roadmap based on your crypto business model!

Incluence goes beyond licensing — we help build sustainable international structures and fintech ecosystems. Explore additional services tailored to your growth.

• Corporate Structuring & Tax Planning. We help optimize cross-border corporate setups with a focus on tax efficiency, IP protection, and regulatory compliance.

• Banking & Payment Solutions. Access to a wide network of EU banks, EMIs, PSPs, and SWIFT providers. We facilitate onboarding, risk profiling, and KYC optimization.

• Nominee & Fiduciary Services. Confidential nominee director, shareholder, and trustee services in key jurisdictions.

• License Maintenance & Renewals. Full administrative and legal support to ensure your license remains valid and compliant with updated laws.

• ICO/STO Legal Structuring. Regulatory classification, whitepaper review, and legal opinions for token issuance across the EU.

Obtaining a crypto license in Lithuania may seem complex, but with the right guidance, the process is smooth and efficient. We provide full support at every stage — from crypto company registration in Lithuania to ongoing compliance after licensing.

Step 1: Company Incorporation

We assist with fast and compliant Lithuania crypto company registration, ensuring your entity is ready to apply for a VASP license in Lithuania.

Step 2: License Application Preparation

Our legal experts prepare all required documentation, liaise with regulators, and streamline the process to obtain a crypto license in Lithuania within the shortest possible timeframe.

Step 3: Regulatory Approval and Compliance Setup

Once your Lithuania crypto license is approved, we help set up AML/CTF frameworks, internal policies, and reporting systems to ensure ongoing compliance.

Step 4: Continuous Support

Beyond licensing, we remain your long-term partner, providing Compliance & Ongoing Support and advisory services to keep your crypto business fully aligned with Lithuanian and EU regulations.