MLRO services in Lithuania

The anti-money laundering compliance officer (MLRO) occupies a key position in the corporate governance structure of any organisation operating in the cryptocurrency sector in Lithuania. He is responsible for the effective implementation and maintenance of a comprehensive anti-money laundering (AML) and counter-terrorist financing (CTF) programme.

This role involves actively managing the assessment and minimisation of potential money laundering risks and developing and implementing strategies to strengthen business processes to prevent illegal activity. The MLRO is required to ensure strict compliance with all relevant legal and regulatory requirements, regularly monitor transactions and customer activity for signs of illegal operations, and coordinate with law enforcement and regulatory authorities.

In addition, the MLRO acts as a consultant to all business units, providing professional advice on strengthening internal controls and procedures. He is also responsible for preparing reports for senior management and supervisory authorities, demonstrating the company’s transparency and compliance with established standards and requirements in the area of financial crime.

Money Laundering Reporting Officer responsibilities

In the role of Money Laundering Reporting Officer (MLRO), a key priority is to develop and maintain effective policies, procedures and processes to combat money laundering and terrorist financing. This role includes the following responsibilities:

  1. Monitoring and Analysis: Continuously monitor and scrutinise customer transactions using advanced analytical tools to identify suspicious activity. It is important to report all suspicious transactions to the relevant regulatory and law enforcement authorities, such as the Financial Crimes Investigation Service and the Bank of Lithuania.
  2. Compliance with Legislation: Keep abreast of changes in legislation and regulatory requirements, as well as industry trends, to ensure that the company’s practices are in line with current requirements.
  3. Internal Co-operation: Work closely with internal stakeholders to provide advice and training on anti-money laundering, fostering a culture of strong compliance within the company.
  4. Risk Management: Responsibility for customer registration and effective management of high-risk segments of the customer base. Prompt response to and management of financial crime threats.
  5. Tool Development: Leading the implementation of tools that provide the company with the ability to identify and manage financial crime risk.
  6. Audit support: Active participation and support in AML audits within the Lithuanian company.
  7. Reporting: Prepare and present reports on MLRO activities to senior management demonstrating the results and effectiveness of the anti-money laundering measures implemented.

This complex role requires not only a thorough understanding of legislative frameworks and best practice, but also a strategic approach to risk management and the organisation’s internal policies.

Work assignments for MLRO services in Lithuania

The position requires compliance with Anti-Money Laundering (AML) and Customer Due Diligence (KYC) requirements and guidelines, adhere to strict corporate standards and guidelines to ensure full compliance with legal and regulatory requirements. Key tasks include:

  1. AML and KYC Compliance: Ensuring strict compliance with all AML and KYC requirements through the implementation and continuous updating of relevant policies and procedures.
  2. Regulatory Compliance: Ensure compliance with regulatory requirements in areas such as financial crime, information security and anti-bribery by regularly reviewing and updating internal guidelines and standards.
  3. Proactive Updating of Procedures: Developing and updating internal procedures to prevent the use of business for money laundering purposes and monitoring the effective implementation of these policies at all levels of the organisation.
  4. Implementation of Policies and Procedures: Disseminate and implement approved anti-money laundering policies, controls and procedures throughout the company.
  5. Interaction with Regulators: Act as a key point of contact for liaising with Lithuanian regulators and deal with formal and informal requests for information.
  6. Reporting: Prepare and submit regular compliance reports to the company’s management reflecting the current status and results of the implementation of regulatory requirements.
  7. Monitoring Changes in Legislation: Continuous study of regulatory rules and changes in legislation to promptly respond to innovations.
  8. Reporting: Developing detailed reports on relevant data for management analysis and evaluation.

MLRO in Lithuania – general information

In the context of the dynamically developing cryptocurrency market, the role of the Money Laundering Reporting Officer (MLRO) is of particular importance, providing the basis for the sustainability and growth of businesses related to virtual assets. In Lithuania, as a member of the European Union, special attention is paid to adaptation and compliance with EU directives, as well as recommendations of international organisations such as the Financial Action Task Force (FATF) and the Council of Europe’s Committee of Experts on the Evaluation of Anti-Money Laundering and Countering the Financing of Terrorism (MONEYVAL).

Key aspects of MLRO’s role in the Lithuanian crypto business:

  1. Risk Management: MLRO is responsible for identifying, assessing and managing the risks associated with money laundering and terrorist financing in cryptocurrency transactions. This includes developing and implementing effective AML/CFT strategies and policies that comply with both national and international requirements.
  2. Regulatory Compliance: Ensuring strict compliance with all relevant legal and regulatory requirements is the foundation of a company’s defence against legal risks and sanctions. The MLRO should ensure that all company operations and business processes are scrutinised to ensure compliance.
  3. Training and Development: Maintaining a high level of awareness and competence within the company on AML and CFT issues is critical. MLRO organises regular training and workshops for employees, increasing their ability to recognise and prevent potential threats.
  4. Interaction with Regulators: The MLRO acts as the main point of contact between the cryptocurrency company and regulators. This includes providing all necessary reports and information, as well as participating in discussions on improving the regulatory environment for cryptocurrencies.
  5. Transparency of Transactions: The importance of transaction transparency cannot be underestimated, especially in the cryptocurrency industry where anonymity can facilitate illegal activities. MLRO ensures that all transactions are transparent enough to be tracked and audited.


The introduction of a qualified AML/CFT specialist into a cryptocurrency company’s team is not only a requirement, but also a strategic decision that contributes to building trust and security both within the company and among its clients and partners. Effective implementation of AML/CFT policies and procedures under the guidance of an MLRO helps minimise risks and contributes to the long-term stability and success of a crypto business.

Key responsibilities of MLRO in Lithuania

In the Money Laundering Reporting Officer (MLRO) position, the key tasks are to develop, maintain and continuously improve Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) policies and procedures. Your key responsibilities include:

  1. Development and Maintenance of Policies and Procedures: Establish and regularly update internal control policies, procedures and measures that comply with applicable laws and regulatory requirements. This provides the basis for all AML/CFT activities in the organisation.
  2. Training and Consultations: Organising targeted training and consultations for company employees on AML/CFT risks, policies and procedures. This contributes to raising the awareness and competence of the company’s
  3. Risk Assessment: Conduct regular risk assessments of the company’s AML/CFT compliance programme, including the Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) processes.
  4. Monitoring and Investigations: Tracking and analysing suspicious transactions or activities, ensuring that any suspicious activity is reported to the appropriate authorities in a timely manner.
  5. Interaction with Regulators: Acting as the main point of contact for regulators, providing necessary recommendations and reports on AML/CFT compliance issues.
  6. Work with Stakeholders: Collaborate with internal departments to identify and minimise potential money laundering risks across the company’s various business units and products.
  7. Improved Transaction Monitoring: Revise and optimise the transaction monitoring software to detect unusual activity patterns.
  8. Keeping Management Informed: Provide regular updates on the status of AML/CFT compliance to senior management and the board of directors.
  9. Monitoring Changes in Legislation: Continuous monitoring of changes in AML/CFT laws and regulations, as well as industry trends, to ensure that the company’s programme complies with current requirements.
  10. External Partner Management: Oversee and manage relationships with external service providers and partners supporting the company’s AML/CFT compliance programme.

These responsibilities form a comprehensive approach to AML/CFT risk management and compliance, helping to protect the company from financial and reputational risks.

MLRO in Lithuania work tasks

The position of Registered Money Laundering Reporting Officer (MLRO) in a Lithuanian company providing virtual currency exchange or wallet storage services is to implement and maintain a comprehensive Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) programme. This includes the following key responsibilities:

  1. Policy Development and Implementation: Create, implement and continually update policies, procedures, risk assessments and registers specific to Virtual Asset Service Provider (VASP) operations.
  2. Comprehensive Training and Consultancy: Provide training and advice to company employees on AML and CFT risks, policies and procedures.
  3. Risk Assessment: Regular risk assessment of the company’s activities to ensure compliance with AML/CFT legislation and regulations.
  4. Monitoring and Investigations: Oversight of the AML/CFT compliance programme, including monitoring and investigation of suspicious transactions.
  5. Interaction with Regulatory Authorities: Acting as the main point of contact for enquiries from regulatory and law enforcement authorities related to money laundering activities.
  6. Co-operation with Internal and External Stakeholders: Effective co-operation both internally and with external stakeholders to ensure compliance with AML/CFT
  7. Monitoring Changes in Legislation: Continuously monitor changes in AML/CFT laws and regulations and provide expert advice to senior management on the implications for compliance.
  8. Management of External Audits and Inspections: Organising and overseeing external audits and regulatory body inspections relating to AML/CFT

These responsibilities require a thorough understanding of Lithuanian legislation, including the Lithuanian AMTF Prevention Law, as well as direct liaison with the Financial Crimes Investigation Service of the Republic of Lithuania (FCIS). It is also important to be able to react quickly to changes in legislation and regulations to ensure continuous and effective compliance.

Duties of a KYC/AML officer

As a KYC/AML officer at a Lithuanian cryptocurrency company, your primary anti-money laundering (AML) and counter-terrorist financing (CFT) responsibilities and procedures cover a wide range of activities:

  1. AML/CFT Programme Development and Support: You will assist in the development, implementation and maintenance of an AML/CFT programme, including the formulation of internal policies, procedures and risk registers.
  2. Transaction Analysis and Monitoring: Organise the collection and analysis of information on suspicious transactions or transactions with a high risk of money laundering or terrorist financing.
  3. Filing Reports: Ensuring that written compliance statements are filed with the management of a company registered with the Lithuanian Commercial Register.
  4. Suspicious Activity Recording and Reporting: Maintain records of high-risk customers and immediately report any suspicious activity to the authorities.
  5. Risk Assessment System: Develop and maintain a risk assessment system for products and services, customers and other aspects related to money laundering.
  6. Personnel training: Monitoring and implementation of an ongoing AML training programme for the company’s employees.
  7. Internal Policies and Procedures: Informing and reporting to senior management on the status of internal AML policies and procedures.
  8. External Audits and Inspections: Organise and conduct audits and inspections conducted by external organisations and develop compliance recommendations.

KYC/AML procedures for suspicious transactions:

  • When establishing a business relationship with a new client.
  • When making a cash payment of more than €15,000.
  • When authenticating documents or data, if there is doubt.
  • If there is suspicion of money laundering or terrorist financing.

Suspicious Transaction Reports (STR/CTR):

  • Immediately report to the FCIS if a suspicious transaction is suspected or attempted by the client.
  • Suspend the operation and report to the FCIS within 3 working hours of the suspension.
  • Immediate sending of information to FCIS within 1 working day if criminal activity is suspected.

Reports should be submitted through the electronic government gateway in Lithuanian language, with necessary authorisations from the FCIS.

These actions and procedures form a rigorous and effective strategy to combat financial crime within your company, maintaining compliance with Lithuanian and international legislation.

Main provisions

The KYC/AML Compliance Officer plays a critical role in ensuring that a cryptocurrency company complies with the legal and regulatory requirements necessary to obtain and maintain a single cryptocurrency licence in Lithuania. This specialist is responsible for a number of key functions which include:

  1. Developing and Maintaining a Control System: Implementing and updating internal control systems and tools to detect, monitor and report suspicious transactions related to money laundering or terrorist financing.
  2. Client Identification and Verification: Implementation of KYC procedures, including document requirements, verification of income sources, verification of customer residency, and methods of document authentication.
  3. Document Retention: Ensuring that the retention requirements for documents provided by clients are met in accordance with regulations.
  4. Interaction with Regulators: Acting as the main point of contact for regulators, filing required documents and reports, maintaining a transparent and open dialogue with supervisory authorities.
  5. Personnel Training and Education: Developing and conducting educational programmes for the company’s employees on AML and KYC issues, strengthening awareness and understanding of the importance of these procedures.
  6. Review and Audit: Organising internal and external audits, ensuring all operations comply with AML/KYC requirements.

Professional Requirements for the Candidate:

  • Education and Experience: Graduate degree in finance, law or related discipline, AML/KYC experience, preferably in the cryptocurrency industry or financial services.
  • Professional Skills: Knowledge of Lithuanian legislation and international anti-money laundering standards, ability to analyse, assess risks and make decisions.
  • Personal Qualities: Reliable, responsible, ethical, ability to work in stressful situations.
  • Regulator’s approval: The candidate must be approved by the regulator, which implies verification of his/her professional and personal background.

 Employment of KYC/AML officer in Lithuania

Regulated United Europe offers the services of an experienced KYC/AML compliance specialist who has all the necessary knowledge and skills to ensure that your cryptocurrency project complies with the requirements of the regulator and Lithuanian legislation. Having a qualified specialist greatly simplifies the process of obtaining a licence and contributes to the successful development of your virtual currency business.

Assistance in selecting a KYC/AML specialist in Lithuania 2,000 EUR


A KYC/AML specialist (Compliance Officer) may be either an internal employee of the company or a member of the management structure, including the Board of Directors. It is also possible to engage the services of an external company to fulfil these functions. It is important that it is the natural person with a Lithuanian identification code who can report suspicious financial transactions to the regulator. If compliance tasks are assigned to a unit, its head should be appointed as a contact person and be responsible for compliance.

The compliance officer should report directly to the board of directors of the financial organisation. This position provides him or her with the necessary authority, access to resources and information that is critical to fulfil his or her responsibilities. The AML officer should also actively co-operate with government agencies, such as FCIS, to effectively combat money laundering and terrorist financing.

Yes, KYC/AML experience is desirable for this role. The candidate must possess relevant education, professional skills, personal qualities and an impeccable reputation. These attributes are essential to effectively fulfil the responsibilities. The appointment of a professional requires approval from the FCIS, which verifies the candidate's qualifications and suitable profile.

Failure to comply with AML requirements may result in serious consequences, including revocation of licences and permits to carry out financial activities. In addition, if deficiencies are identified during regulatory inspections, the company may face the need to remedy the deficiencies identified, as well as financial penalties and other sanctions from the regulator. This emphasises the importance of robust compliance management and compliance with all regulatory requirements.

A compliance officer is critical for any cryptocurrency company, as these organisations face unique risks related to money laundering and terrorist financing. In Lithuania, as in many other jurisdictions, having such a specialist is mandatory to fulfil local legal requirements. This specialist is responsible for analysing information on suspicious transactions, submitting relevant data to the FCIS, regularly informing the management team of legal requirements and performing other compliance-related tasks.

Having a qualified KYC/AML officer in the company is one of the main conditions for obtaining a crypto licence in Lithuania. A KYC/AML officer ensures that the company complies with all regulatory requirements related to customer identification and anti-money laundering measures, which is a key factor for successfully obtaining and maintaining a licence.

In order to find a suitable KYC/AML specialist, one can turn to the services of specialised HR agencies that offer professionals with relevant knowledge and experience in financial technology and compliance. Agencies such as Regulated United Europe are able to provide qualified professionals familiar with the legislation and requirements of the regulator in Lithuania.

Yes, obtaining a cryptocurrency licence in Lithuania requires an MLRO or KYC/AML professional to be a permanent resident of Lithuania. This requirement is due to the need to communicate effectively with local regulators and law enforcement agencies, as well as to ensure proper monitoring and reporting under Lithuanian law.

Overall, having a competent KYC/AML professional is integral to the successful operations of any cryptocurrency company, especially in a regulated jurisdiction such as Lithuania.

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At the moment, the main services of our company are legal and compliance solutions for FinTech projects. Our offices are located in Vilnius, Prague, and Warsaw. The legal team can assist with legal analysis, project structuring, and legal regulation.

Company in Lithuania UAB

Registration number: 304377400
Anno: 30.08.2016
Phone: +370 661 75988
Email: [email protected]
Address: Lvovo g. 25 – 702, 7th floor, Vilnius,
09320, Lithuania

Company in Poland Sp. z o.o

Registration number: 38421992700000
Anno: 28.08.2019
Phone: +48 50 633 5087
Email: [email protected]
Address: Twarda 18, 15th floor, Warsaw, 00-824, Poland

Regulated United Europe OÜ

Registration number: 14153440–
Anno: 16.11.2016
Phone: +372 56 966 260
Email:  [email protected]
Address: Laeva 2, Tallinn, 10111, Estonia

Company in Czech Republic s.r.o.

Registration number: 08620563
Anno: 21.10.2019
Phone: +420 775 524 175
Email:  [email protected]
Address: Na Perštýně 342/1, Staré Město, 110 00 Prague

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