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LT (LT) · Module W7 · Derived Confidence: Probable

LT: Legal & Litigation

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AML/CFT failings are the dominant driver of LT EMI licence revocations: Transactive Systems UAB (EUR 280k fine + revocation), PAYRNET (insolvency, EUR 7m irrecoverable intra-group payment, criminal referral), Eurojust-coordinated ~EUR 2bn laundering case.

Horizon · 2026-10-01 In force (commenced)EMI Verified Payments capital-adequacy restoration deadlineIn force (commenced)
Standing sub-brief · as of 27 June 2026249 words · last cycle 2026-09-28

Legal & Litigation

Enforcement is an active and escalating theme for the Lithuanian payments market. The Bank of Lithuania determined that EMI Transactive Systems UAB seriously and systematically infringed AML/CFT requirements, imposing a EUR 280,000 fine and revoking its licence; the firm had been the second-largest EMI/PI by 2022 turnover at EUR 13.1 billion and had failed to properly identify clients and apply enhanced due diligence. The Transactive case sets the enforcement bar for the hub and confirms that AML failings are the dominant driver of Lithuanian EMI licence revocations. It pairs with the PAYRNET revocation — driven by insolvency, an irrecoverable EUR 7 million intra-group payment and a criminal referral — and with the Eurojust-coordinated laundering case of approximately EUR 2 billion.

The litigation and enforcement record carries illicit-finance significance beyond the payments-instrument lens, and the AML use dimension of these cases is routed to the Sentinel (sentinel.gi) as a cross-reference rather than treated as a WPM conclusion. Within the payments view, the relevance is the supervisory enforcement bar and the structural signal that AML control failures, not prudential or conduct breaches, are what most often costs a Lithuanian EMI its licence.

Outlook

The W7 trajectory is escalating. The enforcement intensity is high and the supervisory framework is strengthening in parallel through information-sharing reform, Resolution No 03-33 and DORA. The forward watch item is whether the pace of AML-driven revocations continues as the consolidation phase proceeds, and how the strengthened information-sharing regime affects detection and enforcement cadence.

Periodic update · new data 2026-09-28

Legal & Litigation

The Bank of Lithuania has ordered electronic money institution Verified Payments to restore capital adequacy by 1 October 2026, and pending a separate decision has barred it from taking new clients, encumbering assets, or lending. This is an ongoing supervisory action rather than a concluded matter: the restriction is explicitly described as provisional pending a further Bank of Lithuania decision, meaning the ultimate outcome for Verified Payments — whether restoration of capital adequacy resolves the matter, or whether further restrictions follow — remains open.

Alongside this specific action, the Bank of Lithuania has opened a consultation on amending its fine-calculation procedure and minor-breach criteria, a procedural development that would affect how future enforcement penalties are calculated and categorised across the payments sector generally, separate from the Verified Payments matter itself. Together, these two developments indicate an escalating legal and litigation posture from the regulator this cycle: an active case against a specific under-capitalised entity, combined with a broader procedural reform to the enforcement-penalty framework.

The 1 October 2026 deadline is the clearest near-term marker: whether Verified Payments restores capital adequacy by that date will determine whether the Bank of Lithuania proceeds with further restrictions or eases the current ones. The outcome of the fine-calculation-procedure consultation would separately signal whether the regulator intends a more calibrated or a more stringent enforcement-penalty framework going forward.

Sources and findings (4 unique sources · R-3/R-4)
  1. [W7-E1] T1 Derived: Confirmed in_forcehttps://www.lb.lt/en/news/transactive-systems-uab-faces-fine-and-licence-revocation re-verified

    The Bank of Lithuania determined that EMI Transactive Systems UAB seriously and systematically infringed AML/CFT requirements, imposing a EUR 280,000 fine and revoking its licence; the firm had been the second-largest EMI/PI by 2022 turnover at EUR 13.1 billion and failed to properly identify clients and apply enhanced due diligence.

  2. [W7-E2] T1 Derived: Confirmed in_forcehttps://www.lb.lt/en/news/licence-of-uab-payrnet-revoked-for-serious-violations-bankruptcy-proceedings-to-be-initiated re-verified

    The Bank of Lithuania revoked the licence of EMI UAB PAYRNET for serious, systematic and multiple violations, found it insolvent after an irrecoverable intra-group payment of more than EUR 7 million, and moved to initiate bankruptcy proceedings and refer the matter to law enforcement.

  3. [W7-E3] T3 Derived: Probable in_forcehttps://resources.fenergo.com/blogs/scandal-as-a-service-aml-lessons-from-lithuania-s-2-billion-case re-verified

    A Eurojust-coordinated case described a Lithuanian EMI, shut down in 2022 for AML non-compliance with its licence revoked, that had allegedly laundered an estimated EUR 2 billion since 2017 via a global network of shell companies.

  4. [W7-E4] T1 Derived: Confirmed in_forcehttps://www.lb.lt/en/news/bank-of-lithuania-urges-electronic-money-and-payment-institutions-to-comply-with-capital-requirements re-verified

    The Bank of Lithuania publicly disclosed capital-requirement breaches by three EMIs and one PI as a mild enforcement measure, with shortfalls of between EUR 4,000 and EUR 77,000 subsequently remedied.