Hubert Rachwalski von Rejchwald

🚨📝 October 27, 2025. #MiCA #CryptoLicensing #Lithuania. MiCA licensing status update - the Bank of Lithuania (BoL) issued a reminder that the transitional period for crypto-asset service providers ends on 31 December 2025. After that date, only licensed providers will be allowed to offer crypto services in Lithuania. 🔍 Key Takeaways ▶️ Almost 50 license applications have been submitted since January 2025 - but many were incomplete or unprepared for licensing. ▶️ Only one company has received a crypto service provider license so far Robinhood. ▶️ Over 10 applications are currently under review, with the regulator aiming to complete assessments before year-end. ▶️ The majority of new applications filed in recent weeks fail to meet even basic requirements, raising questions about applicants’ competence. ▶️ Unlicensed operators must return client assets and inform customers about service termination before December 31. ▶️ The Bank of Lithuania can block websites of unlicensed entities and add them to a public list of illegal providers. ▶️ Customers are advised to check whether their provider is applying for a license and, if not, move funds to a supervised, licensed company. 🤷‍♂️ The So What? #CASPs and #Investors should: ✅ Finalise or submit complete MiCA-ready applications without delay. ✅ Inform clients clearly about next steps if not pursuing a license. ✅ Ensure all crypto holdings are transferred to licensed custodians or self-hosted wallets before the deadline. ✅ Treat this as a signal - the regulator is serious about cleaning up the market and will act on non-compliance. 📩 How many Lithuanian crypto firms do you think will cross the finish line by year-end? Let’s see how this transition reshapes the market. #MiCAR | #Lithuania | #CryptoRegulation | #Fintech | #Licensing | #Compliance | #CASP | #BankofLithuania

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The European Banking Authority (EBA)’s latest opinion underscores a challenge many fintechs are facing: as they scale fast, their #AML compliance infrastructure is having trouble keeping up. It highlights a concern that many firms are deploying compliance technology without the proper controls, governance, or experience to match. This can be a challenging dynamic to navigate, but at Hawk we’ve also seen what’s possible when our customers make compliance a strategic priority. As a true partner, we are always there to translate our customers' compliance risk assessments into effective technology-based controls. #AML #fintech #compliance #financialcrime

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A recent incident highlights a major flaw in digital compliance systems during KYC (Know Your Customer) checks. A Polish researcher used ChatGPT-4o to generate a fake passport with realistic details and photo. Surprisingly, the fake document passed identity verification on a platform that uses standard ID and selfie checks. This exposes a serious vulnerability in current KYC systems when facing AI-generated forgeries. It’s a wake-up call for financial institutions and fintech companies to upgrade their verification processes with stronger, multi-layered security.

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Yesterday, AMLA - the new European Anti-Moneylaundering Agency - started its work. AMLA is a big opportunity to fix what’s broken in Europe’s fight against financial crime. If I had 6 wishes for them (from a fintech, RegTech and digital banking lens), here’s what I’d ask: 1️⃣ One consistent AML rulebook for Europe: End the patchwork. No more national gold-plating. Let fintechs and banks operate cross-border with one clear, risk-based standard. 2️⃣ Accelerate RegTech adoption: Encourage the use of AI, network analytics and modern transaction monitoring tools - not just in banks, but also in supervision. Fraudsters adapt fast. Regulators and financial institutions need to move even faster. That means better frameworks for onboarding new technologies, including sandbox environments for fast testing and validation. 3️⃣ Proportionality for new and small players: A 10-person fintech shouldn’t face the same compliance burden as a Tier-1 bank. Let’s enable innovation without killing it through regulation. 4️⃣ Real-time, cross-border intelligence sharing: Financial crime doesn’t stop at borders. AMLA should drive seamless data sharing between FIUs and supervisors - and encourage standardized APIs that fintechs can connect to. 5️⃣ Clear guidance for crypto and digital assets: Let’s stop the grey zones. Fintechs need clear, actionable rules on travel rule compliance, VASP supervision and DeFi-related risks. Digital assets are here to stay. 6️⃣ Stronger public-private partnerships Banks and fintechs see the patterns first. AMLA should foster joint typology development and real-time risk signal sharing - beyond just filing suspicious transaction reports. 7️⃣ Fix the staffing crisis at national FIUs: Financial crime prevention doesn’t end with the banks. Too many FIUs remain understaffed and overwhelmed. Banks get fined for SAR filing delays - but even when they file on time, FIUs are often too overloaded to act. Let’s fix that. If AMLA delivers on this, it won’t just reduce financial crime - it’ll also make Europe a safer and more innovation-friendly place to build compliance innovation. I wish them all the best! >> What are your thoughts on this? #banking #fintech #compliance #amla

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🇱🇹The Bank of Lithuania has fined Revolut €3.5 million for deficiencies in #antimoneylaundering (AML) controls. The fine follows a routine supervisory inspection which identified violations and shortcomings in the monitoring of business relationships and #transactions. These deficiencies resulted in Revolut failing, in some cases, to properly identify potentially #suspicioustransactions, in breach of applicable #AML obligations. No confirmed cases of #moneylaundering were identified. However, the inspection revealed procedural weaknesses affecting the overall effectiveness of the internal control system. Revolut operates in the European Union under a Lithuanian banking license and is supervised by both the Lietuvos bankas | Bank of Lithuania and the European Central Bank. The company has signed a settlement agreement with the regulator and has already taken corrective measures. This is the #largestfine ever imposed by the Lithuanian central bank, calculated based on the severity of the violations and the revenues of Revolut Holdings Europe. #compliance #complianceofficer #followthemoney #dirtymoney #duediligence #kyc

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