Represented ABC Projektai in a dispute with the Bank of Lithuania over the annulment of the strictest supervisory measure

Our Dispute Resolution lawyers represented the payment institution ABC Projektai in an unprecedented dispute against the Bank of Lithuania, which centered on fundamental questions of the legality and proportionality of the supervisory authority’s decision. After the Bank of Lithuania revoked the company’s payment institution licence in April 2020, the client faced existential risks: suspension of operations, loss of revenue, withdrawal of partners, and significant reputational damage to both the company and its founders in the financial market.

Although in June 2024 the Supreme Administrative Court of Lithuania replaced the licence revocation with a temporary suspension, the client continued to face critical business risks: an undefined regulatory status, lack of continuity in financial services, and severely limited ability for the company’s founders to plan activities in the financial sector. Our task was to ensure that the court reassessed the proportionality of the supervisory measure and imposed a proportionate and adequate sanction.

Our dispute team had been representing the client since April 2020, preparing complaints against the Bank of Lithuania’s decision, initiating and supporting a request to refer the matter to the Court of Justice of the European Union, representing the client in the proceedings in Luxembourg, and continuing the process before Lithuanian courts. After the June 2024 ruling, we initiated the reopening of the proceedings and submitted arguments that enabled the court to reassess the justification of the sanction. The project spanned more than five years and became an exceptional example of how consistent work, strategic insight, and deep EU law expertise can change supervisory authorities’ practices.

After reopening the proceedings, the Supreme Administrative Court of Lithuania adopted a landmark decision – instead of the strictest sanction, ABC Projektai received only a warning and a public notice.

This is the first case in Lithuanian history in which a decision by the Bank of Lithuania to revoke a financial institution’s licence was annulled, and after a temporary suspension, the sanction was reduced to the minimum.

The decision fully restored the client’s regulatory status, enabled reputation recovery, and opened the way to pursue further remedies for the infringement of rights.

This precedent strengthens our reputation as experts in dispute resolution and strategic regulatory projects and demonstrates our ability to effectively defend clients’ interests in complex financial sector disputes and regulatory processes.