Lithuania has implemented the Travel Rule following the EU’s Transfer of Funds Regulation (TFR) and FATF’s Travel Rule. The Lithuanian Financial Crime Investigation Service (FCIS) now requires CASPs to record, retain, and share specific transaction data, including originator and beneficiary information, for all qualifying transactions.
What is the scope of the Travel Rule in Lithuania?
The Lithuanian Travel Rule covers all crypto assets services between CASPs, irrespective of the value, as well as crypto assets services between CASPs and self-hosted wallets.
Per MiCA, CASPs are defined as
(8) “any person whose occupation or business is the provision of one or more crypto-asset services to third parties on a professional basis;
With crypto asset services defined as:
(9) ‘crypto-asset service’ means any of the services and activities listed below relating to any crypto-asset:
(a) the custody and administration of crypto-assets on behalf of third parties;
(b) the operation of a trading platform for crypto-assets;
(c) the exchange of crypto-assets for fiat currency that is legal tender;
(d) the exchange of crypto-assets for other crypto-assets;
(e) the execution of orders for crypto-assets on behalf of third parties;
(f) placing of crypto-assets;
(g) the reception and transmission of orders for crypto-assets on behalf of third parties
(h) providing advice on crypto-assets”.
Who is the supervisory body for CASPs in Lithuania?
Financial Crime Investigation Service (FCIS)
What is the Travel Rule threshold in Lithuania?
EUR 0
Every crypto asset transaction between CASPs must comply with the Travel Rule. There is no transfer value exemption (de minimis threshold) for transactions.
For all transfers, the originating CASP must communicate the following information with each crypto transfer before or simultaneously with the transfer:
originator's name,
originator's distributed ledger address,
originator's address, which must include the name of the country, official personal document number and customer identification number, or alternatively, date and place of birth,
originator's LEI (or an equivalent official identifier for businesses and organisations)
beneficiary's name,
beneficiary's distributed ledger address,
beneficiary's LEI (or an equivalent official identifier for businesses and organisations).
Self-hosted wallets are in scope
Lithuanian regulations set clear expectations for transactions involving self-hosted wallets:
When a self-hosted wallet transfer exceeds EUR 1000, CASPs must verify that the customer owns the wallet.
Regardless of the amount, CASPs must collect basic information for every self-hosted wallet transaction to maintain regulatory visibility.
How to comply with Lithuania's Travel Rule and meet AML requirements
Law No. VIII-275 imposes AML/CTF obligations on crypto businesses.
To comply with these requirements, Lithuanian CASPs must
Conduct customer due diligence by verifying customer identities before providing crypto asset services;
Monitor transactions in real-time and implement software to detect suspicious activity;
Report unusual or high-risk transactions within 24 hours to the FCIS via a Suspicious Activity Report (SAR).
Moreover, Lithuanian CASPs must maintain transaction records for at least 5 years.
When do you need to comply with the Travel Rule in Lithuania?
Now. The Travel Rule is in effect.
Which regulations are applicable to the Travel Rule in Lithuania?
Republic of Lithuania Cryptoassets Markets Law XIV-2879
Law on Prevention of Money Laundering and Terrorist Financing
