You launch a crypto exchange or wallet, and banks refuse accounts. Typical situation: your platform is ready but without a license you can't open a corporate account in the eurozone. Lithuania is one of the few EU jurisdictions where VASP registration takes 2-3 months, not a year. The regulators — FIU and Bank of Lithuania — have clear requirements and a practical approach. However, after high-profile cases, rules have tightened: physical presence, an AML officer, integration with goAML and the Travel Rule are mandatory. We support projects from scratch to obtaining registration turnkey, guaranteeing first-time approval.
Why Lithuania Is Attractive for Crypto Projects?
Lithuania attracts crypto projects with speed and predictability. VASP registration takes 2-3 months, which is 2-3 times faster than an EMI license (6-12 months). Additionally, VASP does not require share capital, while an EMI requires €350,000. The FIU regulator publishes clear guidelines, and the Bank of Lithuania offers a sandbox for testing. But not all projects pass — common mistakes: insufficient AML policy, lack of a local employee, incorrect goAML integration.
How to Choose Between VASP and EMI?
The choice depends on the model: if you exchange cryptocurrency and do not work with fiat — VASP is enough. If you plan to issue electronic money, issue cards, or process SEPA payments — you need an EMI. The difference lies in capital, time, and volume of requirements. Below is a summary table:
| Type | Regulator | Capital | Time to Obtain | EU Passport |
|---|---|---|---|---|
| VASP | FIU Lithuania | none | 2-3 months | no |
| EMI | Bank of Lithuania | €350,000 | 6-12 months | yes |
| Payment Institution | Bank of Lithuania | €125,000 | 6-9 months | yes |
VASP suits startups, EMI suits large-scale projects.
What Is the Travel Rule and How to Comply in Lithuania?
The EU Transfer of Funds Regulation (TFR) requires transmitting sender and receiver data for any virtual asset transfer. Threshold — €0, meaning all transactions are subject to control. Lithuania has recently implemented TFR. To comply, you need to integrate a solution like Notabene — it transmits data via the TRP (Travel Rule Protocol). Otherwise, transactions over €1,000 are blocked (soon the threshold will drop to €0). We set up the Travel Rule for your stack (ethers.js, viem, API).
VASP Registration: Requirements and Nuances
FIU requirements:
- At least one employee in Lithuania with an employment contract (not freelance).
- AML officer — a local specialist with certification (CAMS or equivalent).
- AML/CTF policy with geographic risk, screening against sanctions lists.
- KYC procedures — verification of clients, beneficial owners, politically exposed persons.
- goAML integration — reporting suspicious activities (SAR) within 7 days.
- Travel Rule solution — for data transmission during transfers.
Comparison of Document Requirements
| Requirement | VASP | EMI |
|---|---|---|
| Share capital | none | €350,000 |
| Physical presence | 1+ employee | office + local staff |
| AML officer | mandatory | mandatory |
| IT security audit | not required | mandatory |
| Business plan | brief | detailed 3-year plan |
| Review time | 2-3 months | 6-12 months |
Practical Case: How We Set Up Compliance for a DeFi Project
For one DeFi aggregator, we completed the full cycle in 8 weeks. We used:
- Travel Rule provider: Notabene
- Reporting: goAML API (CTR threshold €15,000)
- KYC: Onfido + Chainalysis for AML screening
- Contracts: Solidity 0.8.x, Foundry
After implementation, the client passed the FIU audit without remarks. The key was correctly documenting the risk assessment and training the AML officer.
Work Process: From Audit to Deployment
- Analysis — we study the business model, determine the license type.
- Design — we develop AML/CTF policy, procedures, documentation.
- Integration — we connect goAML, Travel Rule solution, set up monitoring.
- Testing — internal audit, mock FIU check.
- Deployment — document submission, support until response.
Timelines and Cost
VASP registration: preparation 6-10 weeks + review 2-3 months. Cost starts from €3,000. EMI license: preparation 4-6 months + review 3-6 months. Cost starts from €35,000. Savings when choosing VASP instead of EMI can range from €15,000 to €45,000.
Work Deliverables
We deliver:
- Full document package tailored for FIU or Bank of Lithuania, including AML policy, procedures, and risk assessment.
- Configured goAML and Travel Rule system with integration instructions.
- Access to staff training on compliance procedures.
- Three months of post-registration support.
- Ongoing advisory for audits and regulatory changes.
Our team has 10+ years of experience in blockchain jurisdictions and has helped over 80 projects with crypto licensing and compliance in Lithuania. Contact us for a project assessment. Get a consultation — we will answer all your questions about compliance in the Lithuanian jurisdiction.