Nikita Veremeev
08.01.2026 | 6 min read
Updated: 08.01.2026
As CEO and founder of COREDO, I see every day how entrepreneurs from Europe, Asia and the CIS face the challenges of international expansion: from registering companies in new jurisdictions to obtaining financial licenses and strict compliance with AML requirements. Our experience at COREDO since 2016 covers hundreds of projects in the EU, including the Czech Republic, Slovakia, Cyprus, Estonia and Lithuania, as well as Singapore and Dubai. We help turn these complexities into competitive advantages, ensuring transparency, speed and full compliance.
How the Bank of Lithuania Views Investment Companies in 2026
Over the past 2-3 years the Bank of Lithuania’s approach to investment companies has changed radically. Whereas before the main focus was on formal compliance with AML policies, today the regulator assesses a company’s ability to manage risks in real time.
In COREDO’s practice we see that the Bank of Lithuania analyzes not only the documents but also the architecture of the AML system: how risk scores are generated, who makes decisions on EDD, how the rationale is recorded, and to what extent AML is integrated into business processes rather than existing separately.
That is why companies with formally correct documentation but weak operational logic receive remediation requirements at an early stage.
Why Lithuania Leads in Investments in 2026
Lithuania stands out as a hub for investment firms Lithuania, especially in fintech and crypto. The Bank of Lithuania is actively implementing AML requirements Lithuania 2025, harmonizing them with 6AMLD Lithuania and the upcoming AMLR reporting Lithuania. COREDO’s practice confirms: here the minimum capital for investment firms starts at EUR 125 000 for MiFID-licenses, and for a CASP license – from EUR 125 000 to EUR 150 000 depending on services. The COREDO team recently assisted a client from Singapore: we integrated eKYC Lithuania and digital AML onboarding, reducing beneficiary verification time from 4 weeks to 7 days.
Why AML in Lithuania is stricter than in most EU countries
Unlike a number of other EU jurisdictions, Lithuania applies a conservative risk-based approach to investment companies. This is due to the active stance of the Bank of Lithuania and the high concentration of fintech and crypto projects.
In practice this means: deeper verification of beneficiaries, increased requirements for source of wealth and special attention to cross-border flows. COREDO incorporates these expectations into AML design in advance, which allows passing checks without delays.
KYC procedures in Lithuania are evolving under eIDAS standards, requiring multi-factor authentication and video verification.
For KYC in investments in Lithuania the key step is: source of funds verification and source of wealth checks.
The solution developed by COREDO combines APIs from trusted providers with the Bank of Lithuania’s local databases, minimizing false positives and increasing ROI from automation by up to 25% through reduced operational costs.
Typical mistakes of investment companies in KYC in Lithuania
According to our statistics, the main mistakes investment companies make in Lithuania are not the absence of KYC, but applying it at the wrong depth.
Situations often occur when standard CDD is applied to high-risk investors or the decision-making logic for EDD is not documented. The Bank of Lithuania perceives this as a systemic defect, even if the checks themselves were carried out. That is why COREDO implements mandatory documentation of the decision trail for every atypical client.
The role of the MLRO in investment companies: formality or control
In Lithuania the MLRO — is not a nominal position but a key internal control function. The Bank of Lithuania assesses the actual involvement of the MLRO in processes: from client onboarding to closing alerts and filing STRs.
In COREDO projects we build a model where the MLRO has direct access to the board of directors and independence from commercial pressure. This reduces regulatory risks and increases trust from partner banks.
AML officer and MLRO in investment firms
Mandatory Bank of Lithuania AML requirement: the presence of a resident AML officer in Lithuania or an MLRO in Lithuania for investment firms. This specialist is responsible for internal AML control, financial monitoring and reporting obligations under Lithuania’s AML/CTF regime. Our experience at COREDO has shown: a resident MLRO reduces the risk of fines for AML breaches by investment companies — up to 5% of turnover under 6AMLD.
We helped an investment firm from Estonia appoint a qualified MLRO, integrating them into the structure with monthly self-assessment compliance and staff training on FATF recommendations.
For AML for crypto investments in Lithuania, the specifics of the MiCA licence in Lithuania and CASP AML requirements apply. The CASP licence transitional period until 2025 has concluded, but we see that firms with MiCA AML investments gain an advantage in attracting investors from the EU and Asia.
The COREDO team prepared a business plan for a client from Dubai: implementing blockchain AML and AI transaction monitoring provided transaction scoring with 98% accuracy, speeding up license approval by 40%.
AML for investment companies with crypto exposure
investment companies with crypto exposure in Lithuania are under enhanced supervision. In addition to standard AML procedures, the Bank of Lithuania expects the implementation of blockchain analytics, the travel rule and DeFi risk monitoring.
At COREDO we apply a layered approach: on-chain monitoring, off-chain KYC and behavioral transaction analytics. This reduces regulatory burden without restricting the investment strategy.
KYC and compliance for investment companies
How to implement KYC for investment firms in Lithuania? Start with an AML policy that integrates KYC, Lithuania’s AML requirements and beneficiary checks. Standard process:
- Step: Automate digital identification via eKYC with cryptographic protocols.
- Step: Implement source-of-funds verification for investments in Lithuania, checking the transaction chain for compliance with CFT procedures.
- Step: Appoint an AML officer for investments and set up automated AML transaction monitoring in Lithuania with anti-fraud systems.
How the Bank of Lithuania assesses the effectiveness of an AML system
In inspections, the Bank of Lithuania analyzes not the number of procedures, but their effectiveness. Key metrics — alert handling speed, percentage of false positives and the quality of STR reports.
At COREDO we use Precision/Recall metrics to evaluate AML models. This approach allows us to convincingly demonstrate to the regulator that the system works effectively rather than formally.
COREDO’s practice confirms: such a system pays off in 6–9 months. For one investment company from the Czech Republic we conducted a compliance audit in Lithuania, identified gaps in internal compliance and remedied them, preventing fines of up to EUR 1 million.
Preparation for a compliance audit for investment companies in Lithuania includes an AML IT audit and DORA cybersecurity, where COREDO integrates DORA resilience to protect client assets.
What happens after a negative AML inspection in Lithuania
Negative AML findings in Lithuania almost always lead to a mandatory remediation plan. Depending on the severity of the violations, the Bank of Lithuania may restrict operations, prohibit onboarding new clients or initiate an ad hoc audit.
In COREDO’s practice we see that timely remediation significantly reduces the risk of sanctions and allows licenses to be retained without public consequences.
AML systems: risks and ROI
Failure to comply with AML requirements for investment companies in Lithuania in 2025 carries risks: fines for AML violations of investment companies in Lithuania reach 10% of global turnover, plus reputational damage. The AMLA agency is increasing supervision of VASPs, affecting the scaling of crypto investments.
Still, investments in AML compliance for investment companies deliver ROI: automating and implementing eKYC reduces costs by 30–50%, and ROI metrics from digital onboarding and eKYC in Lithuanian investment firms reach up to 200% due to client base growth.
Our experience at COREDO with EMI/PI licenses and fintech compliance (like Paysera) shows: AML risk management in Lithuanian investment portfolios through AI monitoring and incident response ensures sustainable growth.
A client from Singapore scaled their portfolio by 150% after integrating eKYC and digital onboarding into AML in Lithuania, minimizing hidden costs of source of funds verification.
The connection between AML and scaling an investment business
For investment companies, AML in Lithuania is not a limitation but a scaling tool. Banks, funds and institutional investors view a mature AML system as an indicator of business manageability.
In COREDO projects, it was precisely the presence of a transparent AML framework that allowed clients to raise capital faster and enter new markets without repeated checks.
Comprehensive support: registration and licensing
Registration in Lithuania is combined with Legal entity registration in the EU: digital identification of founders under eIDAS speeds up the process to 1–2 weeks.
For high-risk business, including crypto, the COREDO team develops SPV structures with capital structure and an AML business plan. We obtain MiCA compliance and a CASP business plan, integrating the regulatory sandboxes of the Bank of Lithuania.
In Asia, as in Singapore, KYC procedures are similar, but with a focus on sanctions lists. COREDO’s solution for a fintech client combined online verification with account opening, enabling a launch in 3 weeks.
In the CIS and Dubai, we focus on financial transparency and the protection of client assets.
Checklist for an investment company before a Bank of Lithuania inspection
Before interacting with the Bank of Lithuania investment company must ensure that:
- the ownership structure is transparent and justified;
- sources of funds are documented;
- the AML officer is actively involved in processes;
- the IT infrastructure complies with DORA;
- the AML and business strategies are aligned with each other.
The absence of any of these elements increases the likelihood of findings or restrictions.
Partnership with COREDO
COREDO offers a comprehensive package: from registrations and licenses to AML/KYC policies and regulatory audit. We recognize the challenges, new FATF compliance, AMLA and 6AMLD directives require adaptation,, but our solutions, backed by 9 years of experience, enable scaling of investment business in the EU. Contact us: we’ll turn your ambitions into reality.