Fines “Under the Christmas Tree” for Large Payment Companies in Lithuania
December 2025 became a time of shake for European fintech, with the epicenter in Lithuania, where an unexpected shift toward stricter financial compliance occurred. To date, Lithuania has issued the highest number of EMI licenses in the EU and long held a reputation of a relatively moderate jurisdiction for starting payment business.
It’s true that compliance requirements for merchants and companies in Lithuania have always been not that strict as, for example, in the UK. But on the eve of the holiday season, the Bank of Lithuania conducted a series of high-profile inspections that could change the rules of the game in the jurisdiction.
The main players in the regulator’s cases were UAB Monavate and UAB ZEN.COM, whose substantial fines clearly demonstrate: the era of “growth at all costs” is officially over.
Collapse of the BIN Sponsorship Model?
The situation with Monavate exposed the vulnerability of “licensing umbrella” model used by many companies in the region. As of December 29, the Bank of Lithuania ordered the company to cease servicing cards for six partners — including crypto cards from Brighty Digital, Kulipa, and Immersve, as well as traditional fintechs Amnis Europe, KPTRS Investments Limited, and ConnexPay. As a result, tens of thousands of users lost access to their cards in a single day.
The Bank of Lithuania identified more than 50 violations, with the key issue being a loss of control over the end customer chain. Monavate had delegated KYC procedures and AML monitoring to its partners but failed to provide adequate oversight of the quality of these processes. The regulator, meanwhile, demands not just formal agreements with agents but continuous monitoring, audits, and training.
Problems were also found with the storage of client funds — violations in accounting and the separate storage of money create serious risks for both the payment company and its clients. The result: a warning, a fine of €270,000, and a ban on working with six companies.
For other companies, this is a signal that the model of renting a BIN without direct operational control is becoming less viable. Since all six companies using Monavate’s services were suddenly cut off, and all their clients were left without access to their cards. The decision was made on December 23, with full disconnection scheduled six days later — a very short period in which it’s extremely difficult to switch to another card issuer.
Cost of Non-Transparency: ZEN.COM Case
If Monavate is a story about business architecture, then ZEN.COM with €1.8 million fine is more about accumulated compliance debts. The Bank of Lithuania audited country’s second-largest EMI for the period from October 2022 to February 2024 and found more than 60 violations.
The main ones included systemic failures in AML procedures, deficiencies in customer risk assessment, issues with transaction monitoring, and even providing incorrect information to the regulator. Discrepancies between internal data and official reporting cast a particularly strong shadow on the fintech.
The €1.8 million fine is the third-largest in the history of Lithuanian EMIs, following Revolut (€3.5M) and Payeer (€9.3M). But for ZEN.COM, it is especially painful, as it represents a significant portion of annual revenue and 5.3% of its own capital. The company is appealing the decision and claims that all violations have been rectified, client funds are secure, and operations continue as usual.
What to Expect Next?
Currently, Lithuania is in the final stage of preparing for the full implementation of MiCA and new anti-money laundering directives. The regulator has shifted to digital supervision of a new generation, which requires real-time transaction monitoring, full data transparency, and automated AML. Periodic PDF reports are no longer an option that can work.
In our view, in 2026, companies will definitely need to invest in RegTech solutions and automated audits, not just marketing. Bank of Lithuania may be trying to trigger market consolidation for the sake of improving the quality of the remaining players. The cost of maintaining a Lithuanian license will increase significantly, and the model of “renting” infrastructure through intermediaries will become legally complex and potentially problematic for audits.
Next in the spotlight will likely be companies with aggressive exchanges between crypto assets and fiat without proper monitoring of the funds sources. Thus, Lithuania is ceasing to be a “soft, forgiving jurisdiction” and is transforming into a more mature and strategically focused player in the international market.
The source of data for this article was the official website of the Bank of Lithuania.
