Legal Opinion for banks in Lithuania what they want to see

Content

As CEO and founder of COREDO, I see every day how entrepreneurs from Europe, Asia and the CIS face barriers when entering international markets. Registering a company in the EU, obtaining a financial license, or opening a corporate account in Lithuanian banks turns into a marathon of checks where a single flaw in the documents can delay the process by months. Our experience at COREDO since 2016, covering the Czech Republic, Slovakia, Cyprus, Estonia, the United Kingdom, Singapore and Dubai, confirms: a Legal Opinion from an accredited Lithuanian lawyer becomes that very lever that speeds up approval and minimizes risks. In this article I will explain how to properly prepare a Legal Opinion for Lithuanian banks, relying on the practice of the COREDO team and the current requirements of the Bank of Lithuania for 2025.

Legal opinion on Lithuanian banks

Illustration for the section «Legal Opinion in Lithuanian banks» in the article «Legal Opinion for banks in Lithuania - what they want to see»

Lithuanian banks lead the EU in speed and flexibility for fintech, crypto and payment services, but their standards are among the strictest. Lithuanian banks’ requirements for new clients include not only basic KYC but also an in-depth analysis of legal risks.

legal opinion is an official lawyer’s opinion confirming that your structure complies with Basel III, CRR III requirements and local rules. Without it banks reject applications: in our observations, 40% of rejections are related to compliance gaps.

The COREDO team recently assisted a client from Singapore launching an EMI (Electronic Money Institution). The bank required a Legal Opinion to open an account with a Lithuanian bank, focusing on the company’s structure in the Legal Opinion and verification of beneficiaries. We integrated KYC analysis in Lithuanian banks, KYC for corporate clients and beneficial owners verification, which made it possible to open the account in 3 weeks instead of 2 months. This approach not only saves time but also increases ROI: the client scaled operations by 150% in the first quarter.

Legal Opinion Lithuania assesses strategic risks: from sanctions screening to transaction limits. The Bank of Lithuania requires that it cover a fit and proper test for directors, confirming their reputation and qualifications. COREDO’s practice shows: banks look for evidence that your team has passed fitness and propriety checks for board members, including absence of criminal records and industry experience.

Legal Opinion for Lithuanian banks

Illustration for the section «Legal Opinion for Lithuanian banks» in the article «Legal Opinion for banks in Lithuania — what they want to see»

preparation of a legal opinion for an EMI or PI (Payment Institution) – it is not a template, but a document customized to your jurisdiction and business model. The structure of a Legal Opinion for an EMI in Lithuania is built according to the Bank of Lithuania methodology:
  • Introduction and identification of the entity: Full description of the company, founders, UBO (ultimate beneficial owners). Specify enhanced UBO verification with links to eIDAS or video-verification: this is a must-have after the 2025 updates.
  • corporate structure and governance: Analysis of governance requirements, organizational structure in the licensing criteria and internal controls. For high-risk businesses such as crypto, add risk-weighted assets according to prudential standards and EU banking union norms.
  • Compliance section: A detailed review of KYC/AML in Legal Opinion for banks, including AML for banks, AML manager appointment and automated monitoring. Banks check sanctions lists screening and transaction limits for corporate accounts.
  • Financial and operational risks: Assessment of minimum capital in Lithuania (from €350,000 for an EMI), crypto share capital for the crypto license in Lithuania under the MiCA regulation. Mention the CASP transition period until 2025 and differentiated capital.
  • Regulatory aspects: Coverage of DORA compliance in Lithuania for outsourcing rules, operational resilience and cybersecurity requirements. Add climate risk management in prudential standards, as required by CRD VI transposition.
  • Conclusion: Confirmation of the absence of obstacles to opening an account or obtaining a license, signed by a lawyer.
The solution developed at COREDO for an Asian fintech included a pre-application consultation through the Bank of Lithuania Newcomer Programme. We refined the business plan, integrating Basel III into the context of the Legal Opinion, which sped up the submission for Licensing in Lithuania and saved the client 20% on capital.
Legal Opinion component What Lithuanian banks check COREDO practice example
UBO and KYC Enhanced verification, sanctions screening Client from Dubai: verification via API reduced time by 50%
Fit and proper Reputation of directors, experience Verification of 5 UBOs within a week for an EMI
AML/Compliance Automated monitoring, AML manager Integration for PSD2 Open Banking
Capital and risks Minimum capital, risk-weighted assets Optimization under CRR III for crypto
DORA and resilience Outsourcing, cybersecurity Full compliance for scaling
This table reflects what Lithuanian banks want to see in a Legal Opinion for a corporate account: transparency and proactivity.

Legal Opinion for EMI and crypto licenses

Illustration for the section «Legal Opinion for EMI and crypto licenses» in the article «Legal Opinion for banks in Lithuania — what they want to see»
Licensing in Lithuania, the EU gold standard for payment services and crypto. Bank of Lithuania’s requirements for a Legal Opinion are mandatory for PI and EMI licenses. EMI requires capital of €350,000; PI requires €20,000–125,000 depending on services. A Legal Opinion for bank compliance in Lithuania confirms creditworthiness assessment, consumer lending rules and fair customer treatment.

In the crypto sector a Legal Opinion from the Bank of Lithuania is critical for MiCA compliance. With the CASP transition period until January 2025 banks are intensifying scrutiny: they assess climate risk management, solidarity contributions on net interest income and Lithuania’s Basel III metrics.

The COREDO team helped a client from Estonia obtain a crypto license in Lithuania, integrating the Legal Opinion structure for MiCA compliance in Lithuania 2025: with a focus on governance requirements and data confidentiality.

For PSD3 changes and PSD2 Open Banking a Legal Opinion covers automated transaction monitoring, misleading marketing avoidance and a cooling-off period for loans. Our experience has shown: the ROI from a Legal Opinion for accelerating licensing in Lithuania reaches 300%, by shortening the time by 2–3 months.

From registration to scaling

Illustration for the section «From registration to scaling» in the article «Legal Opinion for banks in Lithuania — what they want to see»
Registration is just the start. In 2025, banking requirements for new companies in the EU include a business plan and proof of source of funds. COREDO предлагает полный цикл: от подбора юрисдикции (Lithuania for fintech, Cyprus for holdings) до банковский комплаенс. Мы проводим due diligence, готовим комплаенс-документы для EMI/PI в Литве и обеспечиваем долгосрочную устойчивость через Legal Opinion для PSD3 в ЕС.

One case: a European client was expanding a payments business. A Legal Opinion for outsourcing in Lithuanian banks under DORA confirmed digital resilience, allowing scaling to the EU Banking Union.
How does a Legal Opinion affect ROI when obtaining an EMI license in Lithuania in 2025? It minimizes strategic risks, speeds up the pre-application and avoids fines for non-compliance with CRR III. Is it worth investing in an expedited Legal Opinion? Absolutely: for the Newcomer Programme it halves the cycle.

Final ideas of the strategy

Illustration for the section «Final ideas of the strategy» in the article «Legal Opinion for banks in Lithuania - what they want to see»
A Legal Opinion for CRR III compliance in Lithuania – an investment in the future. Long-term consequences of a non-compliant Legal Opinion under Basel III: account refusals, license delays and reputational losses. With COREDO you get a partner who understands the impact of a Legal Opinion on scaling fintech in the EU. We integrate KYC for corporate clients, prudential standards and solidarity contributions, ensuring transparency.

If you are planning to open an account in a Lithuanian bank or obtain a license, start with a consultation. Our approach is honest: we acknowledge the challenges of sanctions screening and fit and proper, but always offer solutions. COREDO has already helped hundreds of businesses; join them and your project will take off.
LEAVE AN APPLICATION AND GET
A CONSULTATION

    By contacting us you agree to your details being used for the purposes of processing your application in accordance with our Privacy policy.