EMA responds to 4MLD implementation consultation in Lithuania
The EMA submitted a response to Lithuanian consultation on their draft law implementing the 4MLD on 8 July, which concentrated on the implementation of CDD and local point of contact provisions.
We welcomed the implementation of specific e-money thresholds under Article 15 and the reference to any low-risk situations that may qualify for SDD under European guidance. However, we expressed our expectation for it to be made clear that both identification and verification may be postponed within the limits set by Article 15(1) (7).
As Lithuania proposed not to make use of the national optional threshold of EUR 500 for non-reloadable e-money products, we emphasised the importance of taking advantage of this option, in order for the e-money industry to continue providing solutions to the financially excluded and those with limited means.
Regarding the requirement for a local point of contact for each issuer physically distributing products in Lithuania, we set out why this requirement would not be an appropriate means of exercising control over passporting EMIs.
Find more details of the EMA response here.