Bank of LithuaniaFinemedium

European Merchant Bank

Vilnius, Lithuania

In December 2021, the Bank of Lithuania issued a €65,000 fine against European Merchant Bank, a Vilnius-based fintech and BaaS provider. The penalty was imposed for the company's failure to 'manage the risks of high-risk clients' and other anti-money laundering violations. In addition to the financial penalty, the regulator restricted the company's ability to serve both existing and new payment institutions. This action demonstrated regulators' willingness to both fine BaaS providers and curtail their ability to onboard new partners when AML deficiencies are identified. The enforcement preceded a broader wave of regulatory action across Europe targeting BaaS compliance failures.

Verified from source: In December 2021, the Bank of Lithuania issued a €65,000 penalty against Vilnius-based European Merchant Bank for failing to manage the risks of high-risk clients and other AML violations. The regulator also restricted the fintech's ability to serve existing and new EMIs and other payment institutions.

Implications
  1. BaaS providers face dual risk of financial penalties and operational restrictions for AML failures
  2. Regulators may restrict BaaS providers from servicing payment institutions as a remedial measure
  3. Even relatively small fines can signal broader supervisory scrutiny of BaaS models
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