LITHUANIA Law and Practice Contributed by: Donatas Šliora and Marius Matiukas, ADON legal
area, ensuring a streamlined process. Crowd - funding platforms must obtain a licence under this Regulation and are overseen by the Bank of Lithuania for operating across the EU. Before being licensed under the Crowdfunding Regu - lation, crowdfunding service providers were supervised and licensed under national rules; relicensing under the Crowdfunding Regulation has thus had a significant impact on such busi - ness models. Consumer Lending Consumer lending is governed by the Law on Consumer Credit and the Law on Real Estate- Related Credit. Both laws implement different EU rules on consumer lending, namely the EU’s Directive on credit agreements for consumers (the “Consumer Credit Directive” ) and the EU’s Directive on Credit Agreements for Consum - ers Relating to Residential Immovable Prop - erty. Peer-to-peer platforms are supervised and licensed by the Bank of Lithuania and are cov - ered by specific provisions in the above-men - tioned laws; they are heavily impacted by gener - al contract law, consumer protection provisions and the Bank of Lithuania’s guidance on risk management. An upcoming deadline for imple - menting amendments to the Consumer Credit Directive will bring additional harmonisation and further affect areas such as the burgeoning “Buy Now Pay Later” sector. General AML and Cybersecurity Framework Lithuania has strict AML/CTF laws with robust supervision that align with EU best practices, placing a strong emphasis on customer due diligence, transaction monitoring and report - ing. National legislation generally follows the EU’s Directive on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (AMLD).
There is no single dedicated law when it comes to cybersecurity; however, fintechs operate under a combination of Bank of Lithuania guidance and EU Regulations, such as the EU’s Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) (data protection) and DORA (operational resilience). The national cybersecurity framework set out by the Law on Cybersecurity and implementing Directive on measures for a high common level of cyberse - curity across the Union (NIS2) may be relevant. 2.3 Compensation Models Compensation models within the Lithuanian fin - tech landscape operate under a mix of EU-level Directives and national implementation. While contracts between fintech firms and their clients form the basis for fee structures, consumer pro - tection regulations play a significant role in B2C segments. Fintechs dealing with consumers face stricter limits on the fees they can charge and are subject to more extensive disclosure requirements, inspired by EU Directives such as PSD2 and the EU’s Directive on the compara - bility of fees related to payment accounts, pay - ment account switching and access to payment accounts with basic features (PAD). Compensa - tion models might include per-transaction fees (fixed or percentage-based), periodic subscrip - tion fees or hybrid models. B2B agreements often have greater leeway in fee structures for consumer-facing services. Regardless of the customer type, Lithuanian law emphasises fee disclosure. Fintechs are obligat - ed to provide pre-contractual information that clearly outlines pricing. The specific format and detail of this disclosure depend on whether the client is a consumer or a business, mirroring the consumer protection focus of EU law. In certain areas, standardised Fee Information Documents
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