Thomson Reuters | Regulatory intelligence. Country update - Lithuania: Insurance

09.05.2020 Thomson Reuters | Regulatory intelligence. Country update - Lithuania: Insurance

By Partner, Head of Finance industry group Žygimantas Stankevičius and Legal Assistant Tomas Pilkis

 

The Lithuanian insurance market is small compared to other countries of Europe, with the share of assets of insurance companies representing 3.6% of GDP as of 2016. In the year 2018, insurance premiums in Lithuania's insurance market accounted to 878,000,000 euros. In terms of premiums written, the entire Lithuanian insurance market was projected to grow by 5-7% in 2019, to reach up to 932,000,000 euros (a year-on-year increase of 11%).

Lithuania's financial system is open, and its regulatory regime sound. The Bank of Lithuania (BoL) has been the single supervisory authority for the whole financial sector in Lithuania, including the insurance market, since 2012, following the merger of three institutions supervising banking, insurance and capital markets (BoL, Securities Commission and Insurance Supervisory Commission).

At the end of the first half of 2018, insurance services were provided by 20 insurers registered in Lithuania: nine undertakings, were incorporated in Lithuania, and 11 branches of companies registered in other EU countries. Eight of them were engaged in life insurance activities, 12 in non-life insurance activities. 96 insurance brokerage firms were in operation at the end of Q3 2019. However, there are no branches of insurance undertakings of non-EU countries. Over the past decade, the market share held by EU branches has grown, reaching half the market.

Global

Member of IAIS

Lithuania is a member of the International Association of Insurance Supervisors (IAIS), the international standard setting body responsible for developing and assisting in the implementation of principles, standards and other supporting material for the supervision of the insurance sector. Lithuania, as of September 27, 2011, is a signatory of the IAIS Multilateral Memorandum of Understanding (MMoU) for cooperation and information exchange between insurance supervisors.

In 2004, the Insurance Supervisory Authority of Lithuania carried out a self-assessment against the IAIS Core Principles (ICPs). The observance of the 28 principles was assessed, out of which 94% were fully implemented, and 6% of which were partially implemented.

Global regulators, bodies and legislation applicable to country

Lithuania on July 5, 2018 acceded to the Convention on the Organisation for Economic Co-operation and Development (OECD Convention) and became a member of OECD organisation, which mission is to promote policies that will improve the economic and social well-being of people around the world. The OECD publishes economic reports, statistical databases, analyses and forecasts on the outlook for economic growth worldwide, including insurance sector.

The insurance supervisory authority of Lithuania took part in the Financial Sector Assessment Program (FSAP) in 2002 and 2008. Identified shortcomings for the insurance sector at the time were around corporate governance and internal controls of insurance companies, the supervisors' independence, the lack of asset valuation standards, the lack of predictable approach to the imposition of sanctions, insufficient controls on money laundering in the insurance sector and fragmentation in the supervision of the financial markets overall.

Additionally, these shortcomings were addressed in the Law on Insurance through additional regulation on corporate governance, licensing, accounting, market conduct, as well as though the establishment of a new consolidated and risk-based approach on supervision for the entire financial sector.

European

Supervised by EIOPA?

Lithuania has signed MoUs with EU and international organisations (EBA, EIOPA, ESMA, IOSCO and IAIS). Also, Lithuania is a member of the World Trade Organisation (WTO) and the EU with commitments under General Agreement on Trade in Services (GATS) and EU trade agreements. Under GATS, Lithuania has undertaken specific commitments with regards to market access for cross-border supply of maritime and aviation insurance, reinsurance and retrocession and services auxiliary to insurance, such as consultancy, actuarial, risk assessment and claim settlement services (excluding intermediation, such as brokerage and agency).

Does Solvency II apply?

Directive 2009/138/EC of the European Parliament and of the Council (Solvency II) sets out requirements for the activity and supervision of insurance and re-insurance undertakings, applicable as of January 1, 2016, replacing the Solvency I regime which had been in place before. Law on Insurance, transposes Solvency II on the taking-up and pursuit of the business of insurance and reinsurance into national law.

This directive particularly ensures better consumer protection implementing risk-based capital requirements, own risk and solvency assessment, more detailed disclosure on the activity and financial condition, as well as conducting consistent supervision of insurers across the EU, including Lithuania.

Key regulators and rulebooks

Domestic

Since 2012 the BoL is single supervisory authority for all financial markets in Lithuania, including the insurance sector. The general statutory provisions of the BoL are established in the Law on the BoL. According to Article 42(2) of mentioned law, its aim is financial market participants’ compliance with the requirements set in legal acts regulating the financial market.

Such compliance is ensured, inter alia, through the supervision by the BoL of insurance companies, reinsurance companies, branches of foreign insurance and reinsurance companies established in Lithuania, insurance brokerage firms and branches of foreign insurance and reinsurance intermediaries established in Lithuania and through the fulfilment of other functions assigned to the BoL by the Law on Insurance.

The Supervision Service is one of the largest structural units of the BoL. It performs both prudential and market conduct supervision of financial markets. It consists of two separate departments, which helps to avoid conflicts of interest in decision-making procedure: the Prudential Supervision Department (PSD) conducting prudential supervision and the Financial Services and Markets Supervision Department (FSMSD) responsible for market conduct supervision.

The BoL is accountable to the Lithuanian Parliament (Seimas). The BoL reports its activities to the public via its annual report.

The Ministry of Finance of the Republic of Lithuania formulates policy regarding financial markets, financial institutions and their supervision, financial services, insurance, reinsurance and insurance mediation, financial sector stability, financial crisis prevention and management, restructuring of financial institutions, insurance of deposits and liabilities to investors.

In addition to, the Law on the BoL provides for that the Board of the BoL develops a financial market supervision policy, except in cases where in accordance with the provisions of Regulation (EU) No 1024/2013 this is carried out by the ECB.

Laws

The Law on Insurance regulates insurance, reinsurance and insurance mediation activities in Lithuania. In 2003 a new Law on Insurance was adopted ahead of Lithuania's accession to the EU, drafted in accordance with legal acts of the EU, principles, standards and recommendations of the IAIS, the Code of Good Transparency Practice in Activities of Financial Institutions prepared by the International Monetary Fund (IMF), and conclusions of EU, World Bank and IMF experts.

The new Law on Insurance removed limitations on entry from the internal EU market, introduced enhanced financial requirements for insurance companies and established provisions on supplementary supervision of insurance companies belonging to a group of companies and financial conglomerates, in accordance with EU law. Insurance brokers were distinguished as independent insurance intermediaries and insurance agents as dependent insurance intermediaries and detailed regulation on intermediaries' activities was introduced.

In 2010, the Compulsory Insurance Concept was approved by the Government of Lithuania, seeking to ensure consistency and simplicity of the legislative base, analysis of the market and coordination of the terms of compulsory insurances with the market participants concerned. The Compulsory Insurance Concept is approved by the Government and requires that all state institutions take into consideration the provisions of this Concept when drafting legal acts related to compulsory insurance. However, some of the laws concerning compulsory insurance concept have been already adopted in 2001, e.g. Law on compulsory insurance against civil liability in respect of the use of motor vehicles.

In the field of consumer protection, BoL issued in 2012 Guidelines on financial services advertising. The purpose of these Guidelines is to explain advertising requirements set in individual laws applying to types of financial products and assist financial market participants implement those requirements.

Also, in order to monitor financial product market development trends and identify threats for consumers of financial services, financial market participants are required to provide BoL with information about new financial products or changes to already distributed ones, as prescribed by the resolution of the Board of the BoL which entered into force on January 1, 2013. Such requirements are applied to financial products containing the greatest risk to retail clients (investment products, securities, mortgages or their packages).

More regulations covering the sales of life insurance products were established in 2010, enforcing financial consumer protection and providing a procedure to determine the adequacy of the products offered as well as the information requirements before the customers enter into a life insurance contract.

Key rules and requirements

Fit and proper requirements

According to the Law on Insurance, insurers must have a management board, a head of administration and a general shareholders meeting. An insurer may have a supervisory board. They and key function holders (managers responsible for risk management, actuarial, compliance and internal audit) have to comply with the statutory fitness and propriety requirements (requirements). In order to ensure reliable and prudent management they must be of good repute and possess the qualification and experience necessary to properly perform their duties.

Stricter requirements were introduced in 2013 for the governing bodies of insurance companies. On November 14, 2013, the board of directors of the BoL adopted a resolution introducing stricter requirements and the requirement to perform on-going assessment of fitness and propriety for manager and key function holders of insurance companies. The assessment is carried out based on information provided to the BoL in the form of a completed questionnaire and is performed according to the good repute, qualification and experience assessment criterion determined in Article 11 of the Law on Insurance.

Corporate governance

Law on Insurance establishes that a governance system should include an adequate transparent organisational structure with a clear allocation and appropriate segregation of responsibilities and an effective system for ensuring the transmission of information. The system of governance is subject to regular internal review. The Law on Companies of Lithuania stipulates the rights and powers of the company organs (shareholders' General Meeting, supervisory and management boards) as well as the process of adoption of their decisions.

The system of governance includes the compliance with the requirements for fit and proper, risk management, own risk and solvency assessment, internal control, internal audit, actuarial function.

Insurance undertakings are required to have written policies which clearly set out their governance system and which need to be approved by the administrative or management body and revised at least annually or before any significant change is implemented in the system.

Claims

Insurance policy conditions must specify loss evaluation procedure, procedure for calculation of benefits and time periods for their payment, procedure for resolution of disputes between the policyholder and the insurer and must be published on the website of the insurance undertaking. The management board of the insurance undertaking establishes the procedure and rules for reporting, accounting and investigating insured events.

The management board also establishes the procedure for examination of complaints submitted by policy holders, insured persons, beneficiaries and injured third parties as well as the procedure for providing responses to applicants, a description of which must be published on the website of the insurance undertaking. The examination practice regulated by the BoL corresponds to the elements of the OECD Guidelines for Good Practice for Insurance Claim Management.

According to Law on Insurance, if the court rules to initiate bankruptcy proceedings of the insurer, the policyholders of the insurance contracts shall acquire the right to creditors' claims in respect of the share of paid insurance premiums for the period from the termination of the insurance contract on the grounds of bankruptcy proceedings to the original expiry of the insurance contract. Also, the injured third party shall have the right to request directly that the insurer, who has covered civil liability of the person liable for the damage, pays out the benefit.

Financial promotion

The distributor of insurance products must always act fairly and professionally in the conditions and in the interests of the best policyholders when providing services. Recently, BoL has published non-binding explanatory letters on "General good conditions for insurers", regarding obligation for an insurer to manage investment directions in order to achieve the best result for the policyholder, the insured or the beneficiary.

It is forbidden for the distributor to set out remuneration policy which would promote specific insurance product or service, while a distributor could offer another insurance product that is more in line with the needs of the policyholder.

Also the distributor must implement and apply organizational and administrative measures to prevent conflicts of interest which could adversely affect their policyholders. However, if the implementation of these principles are not sufficient, he must clearly disclose the nature or causes of the conflict of interest to the policyholder.

Anti-money laundering

A series of actions have been taken to improve the anti-money laundering (AML) and combating terrorist financing (CFT) framework in Lithuania, including:

  • creation of a governmental working group (AML/CFT Coordination Group);
  • amendments to the Law on the prevention of money laundering and terrorist financing (Law on AML/CFT) in 2014;
  • updated BoL guidelines for financial market participants in 2015;
  • a national AML/CFT risk assessment performed by Financial Crime Investigation Service of the Ministry of Interior of the Republic of Lithuania for year 2018 resulting in action plan and updated criteria on terrorist financing in 2019.

BoL approves instructions aimed at preventing AML/CFT which are intended for insurance undertakings engaged in life insurance activities and insurance brokerage firms engaged in insurance mediation activities relating to life insurance, supervise the activities of these entities related to the implementation of AML/CFT prevention measures and give advice according to the Law on AML/CFT.

Since EU directives regarding AML/CFT requirements have been implemented in the national law, it also covers before mentioned insurance market participant activities whom are subject to the procedures foreseen in the Law on AML/CFT, e.g. CDD, [TP1] EDD, etc.

Licence requirements

Taking into account that, at the time of authorisation, the insurance company being established or authorised must be prepared to comply with all requirements set for it. Nevertheless, when assessing the critical aspects that may determine authorisation, the following basic elements can be singled out:

  • the documents submitted must comply with the requirements of legal acts regulating the activities of insurance company and their supervision;
  • the authorised capital of an insurance company shall not be less than 1,000,000 euros, while the shares of an insurance company shall only be registered and paid up in cash, and shall not be paid up with borrowed funds of funds of illegal origin;
  • the founders of an insurance company must be of good repute;
  • fitness and propriety of heads of an insurance company;
  • the business plan must correspond to the possibilities of the founders (shareholders or holders of voting rights) of the insurance company to implement it, while the prospective insurance company must, at the time of authorisation, be prepared to provide insurance services in a safe and sound manner.

A licence to engage in activities shall be effective in all the other countries of the European Economic Area (EEA), granting the right to engage in insurance or reinsurance activity through exercising the right of establishment and shall be issued for indefinite period of time.

The Lithuania licence to engage in insurance activity shall be granted by the BoL to engage in insurance activity of the entire insurance class or several insurance classes belonging to branches of life assurance or non-life insurance, except when the applicant wishes to engage in insurance activity of only some of the risks belonging to the insurance class (classes).

Capital reserve requirements

In order to ensure that insurance companies continue to be able to fulfil their obligations under their insurance contracts, they are duty-bound to establish adequate technical provisions, invest in appropriate assets and meet statutory solvency requirements. Law on Insurance identifies free assets of an insurance company and those of its assets that serve to discharge all of its liabilities under insurance contracts (e.g. technical provisions). The value of technical provisions correspond to the amount the insurance and reinsurance undertakings have to pay if they were to transfer their rights and duties under its contracts immediately to another undertaking.

The restricted assets need to be segregated from the free assets and should ensure the security, quality, liquidity, profitability and availability of the portfolio as a whole. All assets of the insurance companies need to be invested in accordance with the prudent person principle which includes all other provisions of Article 42 of Law on Insurance, e.g. ensure that the investment is made in the best interest of policyholders, etc.

Asset Liability Management (ALM). Unless otherwise provided for in Law on Insurance and other legal acts, insurance and reinsurance undertakings value assets and liabilities reducing the firm’s risk of loss from not paying a liability on time in accordance with the following rules:

  • assets shall be valued at the amount for which they could be exchanged between unrelated knowledgeable willing parties in a transaction;
  • liabilities shall be valued at the amount for which they could be transferred, or settled, between unrelated, knowledgeable willing parties in a transaction. For the purposes set out in this paragraph, the financial standing of the insurance or reinsurance undertaking shall not be taken into account in valuation of the liabilities.

Insurance undertakings solvency margin

Insurance and reinsurance undertakings must hold eligible own funds covering the solvency capital requirement (SCR). SCR is calculated considering both current activity and planned activity for the next 12 months, as well as the overall risk of an insurance undertaking (insurance risk, market risk, credit risk, operational risk) using either a standard formula or an internal model which needs to be approved by the regulator business.

The solvency capital requirement shows how much capital an insurance undertaking has to hold to ensure that it will be able to cover unexpected losses and meet its liabilities to insurance policy holders within the next 12 months with a 99.5% probability of default. An insurance undertaking must calculate the solvency capital requirement at least on an annual basis, it also has to monitor and ensure coverage of the solvency capital requirement with eligible own funds on a permanent basis.

All the insurance companies providing service in Lithuania meet with the requirements set out by the Law on Insurance according to the BoL insurance market overview of Q3 2019.

The minimum capital requirement (MCR) is the minimum amount of capital needed for taking up and pursuit of insurance business. The minimum capital requirement cannot be below 25% or above 45% of insurance or reinsurance undertaking's solvency capital requirement; however, it cannot be less than:

  • 2,500,000 euros – for an insurance undertaking engaged in non-life insurance activities;
  • 3,700,000 euros – for an insurance undertaking engaged in life assurance activities;
  • 3,700,000 euros – for an insurance undertaking engaged in insurance activities of insurance risks in the insurance classes (insurance against civil liability arising out of the use of land motor vehicles; insurance against civil liability arising out of the use of aircraft; insurance against civil liability arising out of the use of ships (sea and internal waters); general civil liability insurance; credit insurance; suretyship insurance);
  • 3,600,000 euros – for a reinsurance undertaking.

Companies undertake to calculate the minimum capital requirement at least quarterly, monitor and ensure coverage of the minimum capital requirement by eligible basic own funds on a continuing basis and notify the supervisory authority of the calculated minimum capital requirement and coverage thereof.

Capital requirements for Insurance Broker Undertakings

Given that insurance brokers are popular in Lithuania, this guide provides information about this entity. The authorised capital of an insurance broker undertaking may not be less than 18,750 euros, and the equity may not be less than 4% of the insurance premiums income through a financial year payable to insurers and not less than 18,750 euros.

An insurance broker undertaking must insure professional civil liability. The amount of insurance must be not less than 1,250,000 euros per one insured event and 1,850,000 euros for all insured events over a year. The insurance cover must be valid throughout the entire territory of the European Economic Area. An insurance broker undertaking must possess insurance cover for the entire period of its activities.

Insolvency and policy-holder protection

Relevant resolution regime?

As prescribed by the Law on Insurance transposing Solvency II requirements, in case of breach of the SCR and MCR requirements the insurers have the following obligations:

  • insurers are required to inform the supervisor in case the SCR requirement is breached or when there is a risk of non-compliance in a three month period and submit within two months a realistic recovery plan to the supervisor for approval. The supervisor imposes necessary measures to achieve within a six month period (potentially extended to nine months) the re-establishment of the level of eligible own funds covering the SCR or the reduction of the risk profile to ensure compliance;
  • in the event of exceptionally adverse conditions (an unforeseen, sharp and steep fall in financial markets, a persistent low interest rate environment, a high-impact catastrophic event) affecting insurance undertakings representing a significant share of the market or of the affected lines of business, as declared by EIOPA, and where appropriate after consulting the European Systemic Risk Board (ESRB), the supervisor may extend that period by a maximum of seven years, taking into account all relevant factors including the average duration of technical provisions;
  • insurers are required to inform the supervisor in case the MCR is breached or where there is a risk of non-compliance in a three month period. Affected insurers are then required to submit within one months to the supervisor (for approval) a short-term realistic finance scheme to restore within three months the eligible basic own funds at least to the level of the MCR, or to reduce its risk profile to ensure compliance with the MCR.

Product specific legislation

Relevant advisory documentation or other requirements, including tax

Resolution No 03-193 of the Board of the Bank of Lithuania of October 18, 2018, "On the Adoption of the Classification of Life Assurance and Non-Life Insurance Businesses" describe classes and branches of insurance that are used in Lithuania. These classes are set out in Article 7 of Law on Insurance.

Life

The structure of distribution differs in life and non-life insurance products. The main distribution channels for the sale of life insurance products are dependent intermediaries (agents) and banks, as the largest life insurers are part of groups involved in banking activity and/or are leveraging on banks' networks and their capacity to bundle insurance and banking products.

Banks sell packaged insurance and banking products by acting either as insurance intermediaries or as policyholders. The duties of banks (or consumer credit providers) towards clients offered packages of banking and insurance products are prescribed by a BoL opinion, and clients should be granted with the same rights and obligations as clients purchasing insurance as a separate product.

Life insurance premiums paid by Lithuanian residents can be deducted from personal income tax, if:

  • life insurance premiums are paid for his own benefit or for the benefit of his spouse or children until 18 years old or older disabled children;
  • life insurance contracts provide for the payment of insurance benefits not only in the case of an insurance event but also upon the expiry of the insurance contract;
  • the recipient of the premiums is insurance undertakings operating in an EEA member state or an OECD member state.
  • The total amount of deductions (life insurance premiums, pension premiums, professional training, etc.) should not exceed 25% of the individual's taxable income.

Non-life insurance

Non-life insurers tend to have their own sales network and/or depend mostly on independent intermediaries (brokers) who offer similar products by several insurers. Non-life insurance comprises more than 70% of the entire insurance market.

The non-life insurance branch shall comprise the following assurance classes: 1) accident insurance; 2) sickness insurance; 3) land motor vehicles, except for railway rolling stock, insurance; 4) railway rolling stock insurance; 5) aircraft insurance; 6) ships (sea and internal waters) insurance; 7) goods in transit insurance; 8) property insurance against fire and natural forces; 9) property insurance against other risks (except for subparagraph 8 of this paragraph); 10) insurance against civil liability arising out of the use of land motor vehicles; 11) insurance against civil liability arising out of the use of aircraft; 12) insurance against civil liability arising out of the use of ships (sea and internal waters); 13) general civil liability insurance; 14) credit insurance; 15) suretyship insurance; 16) financial loss insurance; 17) legal expenses insurance; 18) assistance insurance.

According to the branches of insurance, insurance contracts may be classified into life and non-life insurance contracts. Non-life insurance contracts shall comprise property, civil liability and health insurance contracts.

Commercial insurance

The main compulsory line of insurance is motor third-party liability (MTPL) introduced in 2002. MTPL insurance is the largest line of business in the non-life insurance market (MTPL written premiums account for 34.6% of non-life insurance as of December 31, 2016). Compulsory professional indemnity insurance is mandatory for certain professions (advocates, bailiffs, notaries, buildings designers and contractors, auditors, assignees in bankruptcy, insurance intermediaries). The size of this line of insurance is small with written premiums of less than 2% of total non-life insurance premiums written.

Reinsurance

In the Republic of Lithuania, the right to engage in reinsurance activity can be exercised by reinsurance company established according to the procedure set by the laws of the Republic of Lithuania: public limited liability companies, private limited liability companies or European companies (Societas Europaea), after being granted a licence to engage in reinsurance activity.

There are no registered reinsurance companies in Lithuania and accepted reinsurance activity is insignificant. As of December 2015, only 6% of insurance was ceded to reinsurers (1.1% of life insurance and 8.4% of non-life insurance).

Enforcement and investigation

Rules of regulatory investigation

The FSMSD of BoL can conduct investigations (for a maximum of 90 days, including on-site inspections) and apply sanctions to the law-breaching financial services providers. Depending on the infringement, the FSMSD can impose warnings and fines, prohibit the financial services provider from engaging in financial services activities and revoke licences. Information about applied sanctions is published on the BoL website.

Complaints procedure

The BoL is responsible for investigating and handling complaints and resolving disputes between consumers and financial services providers. The FSMSD evaluates all complaints about financial services providers, including insurance undertakings. The FSMSD either responds to consumers within 20 working days from the day of registration of the complaint or forwards the complaint to the competent authority within five days of registration of the complaint. Consumers can submit anonymous complaints about financial services providers via the BoL website.

Upon receipt of a complaint, BoL evaluates the subject-matter. Complaints related to a possible breach of legislation by financial services providers are being handled by the Long-term Savings and Insurance Product Supervision Division according to the complaints-handling procedure. Complaints related to contractual provisions and financial requirements trigger a dispute settlement procedure by the Financial Disputes Resolution Division according to the specific legal requirements around extrajudicial investigations of such type of complaints. Complaints related to dual subject matters, i.e., information about a possible breach of law as well as requests to settle individual disputes trigger two different procedures by the previously mentioned divisions.

Redress, including Ombudsman service

Insurance mediation compensation schemes

As of January 2012, the BoL is responsible for the extrajudicial investigation of complaints and the resolution of disputes between consumers (natural persons only) and financial institutions about most financial problems, including insurance disputes.

The procedure for the investigation of disputes between consumers and financial market participants is prescribed by the Law on Consumer Protection. Policyholders need to submit in writing to the financial services provider the circumstances of the dispute and their demand. In case the policyholder does not receive a response within 14 days or the response is not to sufficient, the consumer has the right to submit to the BoL the circumstances of the dispute within one year.

The submission to the BoL needs to comply with the requirements indicated in the description of the Procedure for the Investigation of Disputes between Consumers and Financial Market Participants.

During the investigation, the BoL informs the financial market participant about the consumer’s submission and requests comprehensive written explanations and supporting evidence by the financial services provider within 10 days. The BoL investigates the dispute within 90 days from the consumer’s submission (in case of complex disputes, this timeframe may be extended to 120 days) following the adversary principle: the parties of the dispute must prove the circumstances used as the grounds for their demands or explanations.

The BoL acts as mediator in disputes between the two parties (free of charge) so as to ensure that an agreement that is satisfactory to both parties is reached. If the parties fail to settle the dispute BoL decides upon the substance of the dispute and makes the decision to either fully or partially satisfy the consumer's demands, or to reject them. Such decisions are recommendations and therefore both parties maintain the right to apply to court for the settlement of the dispute according to the judicial procedure.

In 2018, 77% of all disputes settled at the BoL (411) were between consumers and insurers. Compared to 2017 – when 358 disputes were settled (71% of all disputes) – the number of disputes between consumers and insurers has increased.

Data protection

According to the Law on Insurance personal data shall be processed in accordance with the procedure established by legal instruments regulating personal data protection.

Financial crime prevention

Member of FATF? On FATF blacklist?

Even though Lithuania is not a member of FATF, it has its own domestic system to conduct financial crime prevention. In case the supervisory authority receives information about illegal or suspicious activity in the financial market, it conveys the information either to the police (responsible for conducting criminal investigations) or to the Financial Crime Investigation Service of the Ministry of Interior of the Republic of Lithuania (responsible for the investigation of suspicious transaction reports).

Produced by Thomson Reuters Accelus Regulatory Intelligence. For more information please click here.

  Zygimantas BW2 580 72

Žygimantas Stankevičius
Partner, Head of Finance industry group
zygimantas.stankevicius@tgsbaltic.com

 Tomas Pilkis BW580

Tomas Pilkis
Legal Assistant
tomas.pilkis@tgsbaltic.com