National security screening process

Fintech law firm in Lithuania
Sigita Zavišienė

Financial Law, Compliance & AML


Financial and credit sectors are of strategic importance for national security as this is set out in the Law on the Protection of Objects of Importance to Ensuring National Security of the Republic of Lithuania (Law). As activities of the e-money and payment institutions as well as other financial institutions (FIs) fall within a scope of financial and credit sectors, the national security screening has to be completed.

Such national security screening is applicable to those investors that are willing to establish the FI or acquire 25 % or more shares or voting rights in the FI (Investor), should notify the Commission for Coordination of Protection of Objects of Importance to Ensuring National Security (Commission) of such transaction. Upon receipt of such notification, it is the discretion of the Commission to initiate a procedure for the assessment of whether the interest of the prospective investors in FIs comply with the national security interest.

Investor’s notification addressed to the Commission has to be accompanied with:

  • Copy of the Articles of Association, if the Investor is a legal person;
  • Extract from the respective Companies Register regarding the Investor, if the Investor is a legal person;
  • Copy of his/her passport or identity card, if the Investor is a natural person;
  • List of persons, directly or indirectly controlling the Investor (shareholders and the ultimate beneficial owners (UBOs));
  • Copies of the passport or identity cards of the UBOs;
  • List of other legal entities that are directly or indirectly controlled by the UBOs of the Investor;
  • Copies of incorporation documents of the legal entities controlling the Investor;
  • A detailed description of the Investor’s activity and experience in other countries (in the relevant field) as well as business cooperation and partnership with entities from other countries.

The response of the Commission is usually received within 15-20 business days from submission of the notification. The Commission may ask to provide additional information or answers to specific questions.

The positive decision of the Commission has to be submitted together with the licensing documentation to the Bank of Lithuania.

Our advice for the Investors would be: be transparent and open and disclose all information that is required under the procedures of the Commission.

Please note that the information above is of a generic nature. Should you need individual legal advice, please do not hesitate to contact us.

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