Fintech companies holding e-money or payment institution licences are reminded to:
- Assess whether the company’s governance arrangements are in line with the Description* and amend a governance system, if needed.
- Update internal control procedures in relation to safeguarding customers’ funds according to requirements set out in the Description.
- Assess whether contractual arrangements with banks on the safeguarding of the customers’ funds contain all mandatory provisions specified in the Description.
- Conduct an annual audit to assess the efficiency of the internal control system elements for the prevention of ML/TF as required by the Guidelines **.
- Update the process of outsourcing of the operational functions according to the Rules***.
- Review and amend contracts on the outsourcing of the operational functions according to the requirements stipulated in the Rules.
Should you have questions, please contact us!
* Resolution of the Bank of Lithuania Board No 03-106 dated 23 July 2020 on approval of Description of Requirements for Electronic Money and Payment Institutions regarding the Governance Arrangements and Safeguarding of Received Funds
** Resolution of the Bank of Lithuania Board No 03-15 dated 30 January 2020 on approval of Guidelines on the Prevention of Money Laundering and/or Terrorist Financing for Financial Market Participants
*** Resolution of the Bank of Lithuania Board No 03-166 dated 10 November 2020 on approval of the Rules on the Outsourcing Operational Functions of the Financial Market Participants
