71 Electronic Money Institutions and 45 Payment Institutions operate in Lithuania today. The country ranks first in continental Europe in terms of licensed EMIs.

The Bank of Lithuania prepared and approved its position on the right of electronic money institutions (EMIs) and payment institutions (PIs) to access bank accounts opened with credit institutions.

“We hope that this position, agreed on with all market participants, will provide more clarity and help fintechs operate more smoothly as well as allow banks to improve their cooperation with such companies, while maintaining high risk management standards,” said Jekaterina Govina, Director of the Supervision Service of the Bank of Lithuania.

The position seeks to draw the attention of banks operating in Lithuania to the fact that some of their decisions – regarding rejection to open accounts and/or unilaterally closing them, and/or applying restrictions on their access – may cause negative consequences for EMIs/PIs and limit their licensed activities. Such decisions are often based on banks’ goal to properly manage the risk of money laundering and/or terrorist financing. The position aims to ensure that while managing these risks, banks do not violate the right of EMIs/PIs to have accounts with credit institutions and to access them.

The Bank of Lithuania welcomes an opportunity provided by banks to open three types of accounts for EMIs/PIs on their own behalf: a current account, an account for safeguarding funds of EMI/PI clients as well as an account for the execution of payments by EMI/PI clients.

The position also includes the provision that banks must comply with the principles of objectivity, non-discrimination and proportionality in respect to EMIs/PIs, i.e. to ensure that their decisions and other actions relating to the opening (or closing) of accounts are impartial and objective.

In the opinion of the Bank of Lithuania, banks should ensure that extreme measures, such as termination of business relations with EMIs/PIs or refusal to start them on the basis of money laundering and/or terrorist financing risks, are applied only after having assessed the circumstances relevant in a specific case and only when it is impossible to apply other risk management and mitigation measures.

The position presents an opinion on what practice should be followed when closing an account and how banks and EMIs/PIs should cooperate.

The position is available here:

Position of the Bank of Lithuania on the right of electronic money institutions and payment institutions to access bank accounts opened with credit institutions