Please help! EMI for Payouts based in Hong Kong

#2
As a general rule, it's easy to verify if an EMI is licensed in Lithuania. If it isn't easy, it's not an EMI licensed in Lithuania.

Licensed EMIs practically always have their license number on the footer of their websites, often with a link to the Bank of Lithuania.

Absent that, you can just search the company name on Financial market participants There does not seem to be an called UAB AlpsWallet licensed by the Bank of Lithuania.

What they have isn't a license. It's at best a voluntary registration with the Bank of Lithuania, which is not the same as a license. It's possible that they have a license in process but if that's the case, it's not issued yet.

Or they provide regulated services through another company than UAB AlpsWallet. Who knows...
 
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#3
Correct me if I am wrong but VASP's are not licensed by the Lithuanian central bank but are registered with the FCIS instead. Basically its similar to permission granted in UK to i.e a physical currency exchanger where they are not FCA regulated but instead are granted permission to operate and be supervised by HMRC and just have to follow their AML rules. Its basically the most basic of permissions. Whether they have permission as a VASP or not I don't know. Maybe someone can show where to find this .

https://fntt.lrv.lt/en/faq/#accordion-5-sub-86
--- quote start
Can the Service issue a license for virtual currency exchange operators/depository virtual currency wallet operators?

The activities of virtual currency exchange operators and depositary virtual currency wallet operators are not licensed in the Republic of Lithuania.

However, they are obliged to comply with the requirements set out in the Republic of Lithuania Law on Prevention of Money Laundering and Terrorist Financing. The codified requirements can be found on the website of the Service.

--- quote end

The company contacts details and CEO is below and their LEI has lapsed.

https://rekvizitai.vz.lt/en/company/alpswallet/
https://leiworldwide.com/lei_record/984500B52402SADD6771
 
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#4
Well researched @Sols
 
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#9
linusAG said:
I think they blocked all LT visitors by Cloudflare
Click to expand...

Is that even legal in LT i.e banning locals from a service they have been granted permission by LT FCIS to operate in the country? Isn't this then an offshore establishment and a breach of the law?

---- quote start

The Republic of Lithuania Law on Prevention of Money Laundering and Terrorist Financing ("the Law") does not prohibit entities operating as virtual currency exchange operators and/or depository virtual currency wallet operators from carrying out other types of economic commercial activities, but such activities must be unrestricted by the laws of the Republic of Lithuania and must comply with the requirements thereof.

However, we recall that Article 25(8) of the Law provides for a mandatory requirement that a virtual currency exchange operator and/or a depository virtual currency wallet operator must not carry out activities or provide services in another state to such an extent that only functions or services which are not essential by the nature of their activity remain in the Republic of Lithuania and are performed or provided exclusively to customers of another state or, as a matter of fact, they cease to carry out activities in the Republic of Lithuania.

This requirement of the Law was aimed at ensuring that providers of cryptocurrency-related services provide their services in such a way that they do not end up providing functions or services in the Republic of Lithuania that are not essential to the nature of their business or that they cease to carry out their business activities in the Republic of Lithuania in general. The aim was to avoid the perverse practice where Lithuania might be considered as a country of offshore establishment only, while cryptocurrency-related service providers would be operating in other countries, thus avoiding stricter establishment regulation and regulatory arbitrage, but leaving the reputational risk of money laundering and terrorist financing to Lithuania. The aim of this provision was to ensure that the established company would have a real connection to Lithuania and would be accountable to Lithuanian supervisory and control authorities. It should be noted that this provision does not prohibit the exercise of activities and the provision of services both in the European Union and in other foreign states.

---- quote end
 
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