Higher Risk
 
Medium Risk
 
Info n/a
 
Lower Risk
Bilateral exchange of
information Agreements
in place?
Has exchange of tax information agreement in place
with Belgium and, in September, 2009, entered into
an agreement with Russian Federation to copoerate
in fighting money laundering and terrorist financing.
Sanctions:

None applicable

____________________________________________________

Offshore Jurisdiction Blacklists:

Lithuania has a blacklist of over 60 deemed low-tax jurisdictions.
Payments made by Lithuanian companies to foreign companies
registered in any of those jurisdictions are generally subject to a
15% withholding tax.

____________________________________________________

US State Department Money Laundering Report - 2011:

Lithuania is not a regional financial center. Lithuania has
adequate legal safeguards against money laundering; however,
its geographic location makes it a target for smuggled goods and
tax evasion. The sale of narcotics does not generate a significant
portion of money laundering activity in Lithuania. Value added tax
(VAT) fraud is one of the biggest sources of illicit income, through
underreporting of goods’ value. Most financial crimes, including
VAT embezzlement, smuggling, illegal production and sale of
alcohol, capital flight, and profit concealment, are tied to tax
evasion by Lithuanians. There are no reports of public corruption
contributing to money laundering or terrorist financing.

Lithuania has Free Economic Zones (FEZ) in the cities of
Klaipeda and Kaunas. As of yearend 2010, there are 20
businesses operating in the Klaipeda FEZ, and nine in the
Kaunas FEZ. The companies operating in the zones have the
same accounting and identification responsibilities as those
operating outside the zones. Lithuania’s EU accession agreement
permits the indefinite operation of existing free trade zones, but
precludes the establishment of new ones.

DO FINANCIAL INSTITUTIONS ENGAGE IN CURRENCY
TRANSACTIONS RELATED TO INTERNATIONAL NARCOTICS
TRAFFICKING THAT INCLUDE SIGNIFICANT AMOUNTS OF US
CURRENCY; CURRENCY DERIVED FROM ILLEGAL SALES IN
THE U.S.; OR THAT OTHERWISE SIGNIFICANTLY AFFECT THE
U.S.: NO

CRIMINALIZATION OF MONEY LAUNDERING:

“All serious crimes” approach or “list” approach to predicate
crimes: All crimes approach

Legal persons covered: criminally: YES civilly: YES

CRIMINALIZATION OF TERRORIST FINANCING:

Ability to freeze terrorist assets without delay: YES

UN lists of designated terrorists or terrorist entities distributed to
financial institutions: YES

(Please refer to the Department of State’s Country Reports on
Terrorism, which can be found here: http://www.state.
gov/s/ct/rls/crt/)

KNOW-YOUR-CUSTOMER RULES:

Covered entities: Banks, credit unions, and financial leasing firms;
insurance companies and brokers; lawyers, notaries, tax advisors,
auditors, and accountants; investment and management
companies; real estate brokers and agents; gaming enterprises;
postal services; and dealers in art, antiquities, precious metals
and stones and high-value goods

Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: NO

SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:

Covered entities: Banks, credit unions, and financial leasing firms;
insurance companies and brokers; lawyers, notaries, tax advisors,
auditors, and accountants; investment and management
companies; real estate brokers and agents; gaming enterprises;
postal services; and dealers in art, antiquities, precious metals
and stones and high-value goods

Number of STRs received and time frame: 213 in 2009; about 200
-- January through November 2010

Number of CTRs received and time frame: Approximately 700 by
December 2010

MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:

Prosecutions: 16 from January 2010 to December 15, 2010

Convictions: One

Assets forfeited: criminally: Approximately 73 million litas
(approximately $30 million) in 2009; approximately $93 million litas
(approximately $37 million) in 2010 civilly: Not applicable

RECORDS EXCHANGE MECHANISM:

With U.S.: YES

With other governments/jurisdictions: YES

Lithuania is a member of MONEYVAL, a Financial Action Task
Force (FATF)-style regional body. Its most recent mutual
evaluation can be found here: http://www.coe.
int/t/dghl/monitoring/moneyval/Countries/Lithuania_en.asp

ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:

The Government of Lithuania has a comprehensive anti-money
laundering/counter-terrorist financing regime and is continually
enhancing its laws and regulations as necessary to adhere to
international standards.

In 2008, an Irishman was arrested in Vilnius and charged with,
among other charges, seeking to aid a terrorist organization. The
Irishman was apprehended while meeting a Lithuanian agent
posing as an arms dealer. His trial is ongoing.

____________________________________________________

US State Dept Narcotics Report 2011 (introduction):

No report available

____________________________________________________

US State Dept Trafficking in Persons Report 2011
(introduction):

(Tier 1)

Lithuania is a source, transit, and destination country for women
and girls subjected to sex trafficking. There were also government
reports that Lithuanian boys and girls were subjected to forced
theft in foreign countries. Forty percent of identified Lithuanian
trafficking victims are women and girls who are sex trafficking
victims exploited within Lithuania. Lithuanian women are also the
victims of sex trafficking in the United Kingdom (UK), Germany,
Spain, the Netherlands, Greece, Italy, France, and the Czech
Republic. A small number of women from Russia and Belarus are
transported through Lithuania en route to Western Europe, where
they are subsequently subjected to forced prostitution.

The Government of Lithuania fully complies with the minimum
standards for the elimination of trafficking. The government
ensured that all trafficking offenders convicted this year were
sentenced to prison terms commensurate with the gravity of crime
committed. In prevention activities, the government reinstituted its
national working group and adopted innovative new software to
enhance its ability to investigate human trafficking offenses.
However, the Lithuanian government struggled to investigate and
prosecute labor trafficking offenses. The number of victims
identified by the government decreased by approximately 50
percent. The government’s funding of victim assistance programs
increased modestly over the previous year, though it remained
inadequate.

For full report click here

____________________________________________________

US State Dept Terrorism Report 2009

The Lithuanian military was an active participant in multinational
operations against terrorist and insurgent elements. In Iraq,
Lithuania maintained four trainers serving in the NATO Training
Mission-Iraq. In Afghanistan, Lithuania led a Provincial
Reconstruction Team in Ghor Province that is responsible for
maintaining a stable environment throughout the province and
coordinating reconstruction efforts. Lithuania contributed
approximately 215 personnel to NATO’s International Security
Assistance Force.

____________________________________________________

Links:

Worldwide AML Legislation (International Bar Association)
Tables & Rankings
Are there Sanctions in force against it? (UN/EU/US)
N
?
Is it on FATF list of non-cooperative countries?
N
?
Is it on OECD list of uncooperative Tax Havens?
N
?
OECD - Implementation status of Tax Standard
 
?
Is it on EU 'white' list of equivalent jurisdictions?
EU
?
Offshore Finance Center (Original IMF List)?
N
?
Is it on the US Secretary of Treasury list of jurisdictions of
Primary Money Laundering concern?
N
?
Is it on the US Secretary of State list of jurisdictions
identified to be supporters of International Terrorism?
N
?
Is it on US Department of State International Narcotics
Control Majors List?
N
?
US Dept of State Money Laundering assessment (INCSR)
M
?
Government Actions (For further info see INCRS below):
 
?
-  Criminalized Drug Money Laundering?
Y
 
-  Criminalized Beyond Drugs?
Y
 
-  Record Large Transactions?
Y
 
-  Maintain Records Over Time?
Y
 
-  Report Suspicious Transactions?(NMP)?
Y
 
-  Egmont Financial Intelligence Units?
Y
 
-  System for Identifying/Forfeiting Assets?
Y
 
-  Arrangements for Asset Sharing?
N
 
-  Cooperates with International Law Enforcement?
Y
 
-  International Transportation of Currency?
Y
 
-  Ability to Free Terrorist Assets w/o Delay?
Y
 
-  Disclosure Protection "Safe Harbor"?
Y
 
-  Criminalized Financing of Terrorism?
Y
 
-  States Party to 1988 UN Convention?
Y
 
-  International Terrorism Financing Convention?
Y
 
 
Ranking
2011
Ranking
2010
 
Corruption (Transparency International)
50 (out of
183)
46 (out
of 178)
?
Ease of doing business (World Bank)
27 (out of
183)
23 (out
of 183)
?
Further Tables
FATF 40 + 9 recommendations
Mutual Evaluation Report: 2006
C
L
P
N
N/A
    C  -  Fully Compliant ,   
    L  -  Largely Compliant,    
    P  -  Partially Compliant    
    N  -  Non-Compliant
11
17
20
0
1
Legal Systems
 
1. Money Laundering Offence
P
 
14. Protection & no tipping-off
L
2. ML offence – mental element and
corporate liability
L
 
15. Internal controls,
compliance & audit
L
3. Confiscation and provisional
measures
L
 
16. DNFBP – R.13-15 & 21
P
4. Secrecy laws consistent with the
Recommendations
L
 
17. Sanctions
L
5. Customer due diligence
P
 
18. Shell banks
C
6. Politically exposed persons
P
 
19. Other forms of reporting
C
7. Correspondent banking
C
 
20. Other NFBP & secure
transaction techniques
C
8. New technologies & non
face-to-face business
L
 
21. Special attention for
higher risk countries
L
9. Third parties and introducers
L
 
22. Foreign branches &
subsidiaries
P
10. Record keeping
C
 
23. Regulation, supervision
and monitoring
L
11. Unusual transactions
P
 
24. DNFBP - regulation,
supervision and monitoring
P
12. Designated Non-Financial
Businesses and Professions – R.5,
6, 8-11
P
 
25. Guidelines & Feedback
L
13. Suspicious transaction reporting
P
     
Institutional and other
measures
 
26. The FIU
L
 
31. National co-operation
L
27. Law enforcement authorities
P
 
32. Statistics
P
28. Powers of competent authorities
C
 
33. Legal persons – beneficial
owners
P
29. Supervisors
C
 
34. Legal arrangements –
beneficial owners
N/A
30. Resources, integrity and training
L
 
 
 
International Co-operation
 
35. Conventions
L
 
38. MLA on confiscation and
freezing
L
36. Mutual legal assistance (MLA)
C
 
39. Extradition
C
37. Dual criminality
C
 
40. Other forms of
co-operation
P
Nine Special
Recommendations
 
SR.I Implement UN instruments
P
 
SR VI AML requirements for
money/value transfer services
L
SR.II Criminalise terrorist financing
P
 
SR VII Wire transfer rules
P
SR.III Freeze and confiscate terrorist
assets
P
 
SR.VIII Non profit
organisations
P
SR.IV Suspicious transaction
reporting
P
 
SR.IX Cross Border
Declaration & Disclosure
P
SR.V International co-operation
C
 
 
 
*Please note that FATF deems that a country has significant aml deficiencies if any
of the 'Core' Recommendations, R1, R5, R10, R13, SRII, or SRIV are rated either
Partially of Non-Compliant. These are marked in red.

For FATF to remove a country from the regular follow-up process, it has to be rated
Compliant or Largely Compliant in the above mentioned Core Recommendations
and the following Key Recommendations: -        

R3, R4, R23, R26, R35, R36, R40, SRI, SRIII, SRV

Please also note that any risk assessment should take into consideration all
follow-up reports.
LITHUANIA
KnowYourCountry
-  Know Your Customer Provisions
Y
 
-  Criminalized Tipping Off?
Y
 
-  Report Suspected Terrorist Financing?
Y
 
-  State Party to United Nations TOC?
Y
 
-  State Party to United Nations CAC?
Y
 
Local AML News / Sanctions
Tax Information
Business Information
Extracted from IMF Report:  Republic of Lithuania; 2011
Article IV Consultation (November 2011)

Lithuania’s compliance with the international AML/CFT standard, the
Financial Action Task Force’s (FATF) 40+9 Recommendations, was
assessed by MONEYVAL, the FATF-style regional body of which it is a
member, in January 2006. The ensuing AML/CFT assessment report
was adopted by the MONEYVAL Plenary in November of that same
year. Since then it has produced two progress reports, the first of which
was adopted in March 2008 and the most recent report was adopted in
March 2010. At the occasion of Lithuania’s latest progress report the
significant steps taken by Lithuania over the past years were
acknowledged. At the same time the country indicated that it was still
working on amending its Criminal Code to unify its money laundering
definitions, to bring this definition in line with the Vienna and
Palermo Conventions and to ensure dissuasive criminal sanctions
against money laundering. According to the authorities, since the
assessment report was adopted better customer due diligence (CDD)
measures were introduced, including regarding the identification of
shareholders of legal persons, and improvements were made regarding
the obligation to transmit suspicious transaction reports (STRs). They
also stated progress was made in the areas of implementation of UN
instruments and the freezing and confiscation of terrorist assets.
Last Updated:   16 April 2012