Crypto ATM / kiosk operator in Lithuania
Physical kiosks that exchange cash for crypto (and sometimes vice versa). High-cash AML risk profile.
Crypto ATM is conditionally permitted in Lithuania with a local entity, subject to AML obligations and medium licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- Medium
- Last updated
- 2026-07-13
AML Obligations
- Registration with FCIS as a Virtual Currency Exchange Operator (covers fiat-to-crypto and crypto-to-fiat exchange at kiosks).
- Minimum registered share capital of €125,000.
- Appointment of a dedicated AML Officer (MLRO) who must be a permanent resident of Lithuania.
- Comprehensive internal AML/CTF rules aligned with Lithuanian AML Law and EU directives.
- Documented risk assessment specific to the business model.
- Customer Due Diligence (CDD) procedures — identity and verification of customers and beneficial owners.
- Enhanced Due Diligence (EDD) for high-risk customers, PEPs, and complex/unusual transactions.
- Transaction monitoring systems for suspicious activity detection.
- Mandatory reporting of suspicious transactions (SARs) to the FCIS.
- Record-keeping of customer identification data and transactions for at least 8 years.
- Ongoing monitoring of business relationships.
Key Restrictions
- Must be incorporated as a Lithuanian legal entity (e.g., UAB).
- Must maintain a registered office in Lithuania.
- MLRO must be a permanent resident of Lithuania.
- Key personnel (CEO, board members) likely required to have a strong link to Lithuania.
- Crypto ATM/kiosk operations inherently involve cash-in/cash-out fiat handling, which would require the FCIS registration model for virtual currency exchange operators.
- If the operator handles fiat beyond simple exchange (e.g., issuing e-money/receiving deposits), an EMI or PI license from the Bank of Lithuania may also be required.
Key Risks
- High-cash AML risk profile (cash-to-crypto kiosks) may attract heightened FCIS scrutiny and enforcement actions.
- Threshold for cash transaction reporting (if applicable under general Lithuanian AML law) must be complied with — not explicitly detailed in provided facts, creating ambiguity.
- Regulatory ambiguity on whether kiosks require additional licensing beyond FCIS registration (e.g., if deemed money transmission).
- The €125,000 minimum capital requirement is a meaningful barrier for smaller operators.
- Lithuania's registration regime is narrower than a full license, but operators face the same AML obligations and ongoing supervision by FCIS.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Key Regulator: The Financial Crime Investigation Service (FCIS) is the main supervisory body for virtual currency exchange operators and custodian virtual currency wallet operators.
Virtual Currency Exchange Operator:
Registration Regime (FCIS): For virtual currency exchange and custodian wallet operators, Lithuania operates a registration model. This means that once an applicant meets the specified criteria (primarily AML/CTF related) and submits the required documentation, they are registered and allowed to operate. It is generally a less intensive process than obtaining a full financial services license.
Legal Entity: The applicant must be a legal entity (e.g., UAB – private limited liability company) incorporated in Lithuania.
A minimum €125,000 registered share capital is required for both virtual currency exchange operators and custodian virtual currency wallet operators. This requirement was significantly increased in November 2022 from a previous €2,500.
AML/KYC Requirements: Robust internal procedures are paramount:
Internal AML/CTF Rules: Comprehensive written policies and procedures aligned with Lithuanian AML Law and EU directives.
Risk Assessment: A documented assessment of money laundering and terrorist financing risks specific to the business model.
Customer Due Diligence (CDD): Procedures for identifying and verifying customers (individuals and legal entities), beneficial owners (UBOs), and understanding the purpose and nature of business relationships. This includes ongoing monitoring.
Enhanced Due Diligence (EDD): For high-risk customers, politically exposed persons (PEPs), or complex/unusual transactions.
Transaction Monitoring: Systems and procedures to monitor transactions for suspicious activities.
Reporting: Obligation to report suspicious transactions and activities (SARs) to the FCIS.
Record Keeping: Maintaining records of customer identification data and transactions for at least 8 years.
Registered Office: Must have a registered office in Lithuania.
AML Officer (MLRO): A dedicated, qualified Anti-Money Laundering Officer (MLRO) must be appointed. This individual must be a permanent resident of Lithuania. They are responsible for implementing AML/CTF procedures, training staff, and reporting to the FCIS.
Management/Board: While not all board members need to be Lithuanian residents, the company must demonstrate sufficient substance and connection to Lithuania, and the FCIS may require certain key personnel (e.g., CEO, board members) to have a strong link to the country.
Licensing Regime (Bank of Lithuania): For Electronic Money Institutions (EMIs) and Payment Institutions (PIs), a full licensing regime is in place, involving comprehensive assessment of business plans, financial soundness, risk management, governance, and fit & proper checks, with ongoing prudential supervision.
Electronic Money Institution (EMI) License: Allows issuing electronic money and providing related payment services.
Payment Institution (PI) License: Allows providing various payment services (e.g., money remittance, payment initiation, account information services).
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — Crypto ATM/kiosk operators (exchanging cash for crypto and vice versa) qualify as Virtual Currency Exchange Operators under Lithuanian law and must register with the FCIS, incorporate a Lithuanian legal entity with €125k capital, appoint a local-resident MLRO, and comply with comprehensive AML/CTF obligations, with potential additional EMI/PI licensing if fiat handling extends beyond simple exchange.
Questions this verdict aims to answer
- What money-transmitter / kiosk-specific license is required?
- What cash-transaction reporting thresholds apply?
- What enhanced-KYC obligations attach to cash-in / cash-out?