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Andrius Karmonas
Senior Associate

I specialize in banking and finance law, money laundering and terrorist financing („ML/TF“) prevention, and the implementation of international sanctions.

I advise financial market participants on ML/TF prevention compliance and international sanctions implementation. I regularly conduct assessments of ML/TF prevention internal control system elements and enterprise-wide risk assessments and assist financial institutions in developing appropriate internal policies and control procedures related to AML/CTF and sanctions compliance.

In addition, I advise and represent clients seeking to become licensed financial institutions, including crypto-asset service providers.

I also provide ongoing legal support to existing financial market participants on compliance with applicable legal requirements related to the provision of financial services, data protection, operational risk management, and the enhancement of internal control frameworks.

2025
Licensing of crypto-asset service providers
Provision of legal consultation services to entities seeking to obtain crypto-asset service provider licenses under the new Markets in Crypto-Assets Regulation (MiCAR). Services include the preparation or revision of internal policies and procedures related to AML/CTF prevention, implementation of international sanctions, and fraud prevention, aligning them with MiCAR requirements and industry best practices.
2025
Legal Advisory on the Acquisition of an Electronic Money Institution
Conducted legal due diligence of an electronic money institution focusing on AML/CTF and international sanctions compliance prior to its acquisition. Provided legal advice to the acquiring entity and contributed to obtaining the supervisory authority’s (Bank of Lithuania) non-objection for the acquisition of the electronic money institution.
2024
Legal consultations to an electronic money institution on issuance of e-money tokens
Provision of legal consultation services to an electronic money institution in connection with the planned issuance of e-money tokens under the Markets in Crypto-Assets Regulation (MiCAR). The advisory included an assessment of the business model in light of MiCAR and other applicable requirements, as well as the drafting and negotiation of agreements with relevant partners and counterparties to mitigate potential legal and regulatory risks for the electronic money institution.
2024
Licensing of a specialised bank
Provision of legal consultation services and preparation of the necessary documentation and internal procedures for an entity seeking to obtain a specialised bank licence.
2023 - 2024
Bank licensing
Provision of legal consultation services and preparation of the necessary documentation and internal policies for an entity preparing for the bank licensing process.
2023 - 2024
Registration of a immovable property refinancing service provider in the public list of independent credit intermediaries
Provided legal consultations and prepared internal policies and procedures for an entity seeking registration in the public list of independent credit intermediaries acting in accordance with the Republic of Lithuania Law on Credit Relating to Immovable Property. Following the successful registration, continued to provide legal support on the effective commencement of operations and compliance with applicable legal requirements.
2022 – currently
Enterprise-wide ML/TF, international sanctions and fraud risks assessments
Regular performance of enterprise-wide risk assessments for financial institutions and other obligated entities, focusing on ML/TF, international sanctions, and fraud risks. Preparation of comprehensive reports and action plans outlining the risk mitigation measures and steps entities should implement. In addition, provision of tailored legal advice on the procedures and systems that must be implemented, based on the scale and nature of each entity’s activities, for the effective identification, assessment, and management of ML/TF risks, as well as guidance on the practical implementation of such measures.
2022 – currently
Assessments (audits) of the internal control system elements in financial institutions
Regularly conduction of assessments (audits) of the compliance and operational effectiveness of internal control system elements related to AML/CTF in financial institutions and other obligated entities, ensuring alignment with applicable legal requirements. Additionally, performance of evaluations and backtestings of the entities’ solutions in the context of customer onboarding and ongoing monitoring processes.
2022 – currently
Ongoing legal advisory on AML/CTF and implementation of international sanctions
Provision of continuous support to clients in developing and implementing effective AML/CTF compliance programs and systems in line with applicable legal requirements, regulatory guidance, and supervisory expectations. This inter alia includes the ongoing drafting, updating, and adjustment of internal policies and procedures for financial market participants and other obligated entities.
2022 – 2023
Legal advice on licensing and operational issues under the new crowdfunding Regulation (EU) 2020/1503
Representation of multiple clients in licensing processes under the new crowdfunding Regulation (EU) 2020/1503 and assisted them in successfully obtaining the said licenses. Additionally, providing consultations to crowdfunding market participants on the regulatory changes introduced by the new regulation.
2021
Trainings in the field of personal data protection
Organised and held training for employees of financial institutions regarding the application of the GDPR and other issues related to personal data protection.
2019 – currently
Consultation on banking and finance law questions
Legal consultations on operational matters for banks, credit unions, and insurance companies. Consultation, document preparation, and representation for entities seeking to become financial market participants.
2019 – currently
Establishment and licensing of various financial market participants, compliance
Comprehensive legal consultations on licensing and operational matters for Lithuanian and foreign capital companies, preparation of legal documents for clients seeking to provide various payment or investment services and engage in investment activities, as well as consulting on risk identification, assessment, and monitoring for licensed entities.
Education
2018
Vilniaus University, Lithuania (Master’s degree in Law)
Professional activities
from 2024
Law firm Šenavičius ir partneriai RESPONSE, Senior Associate
2021-2024
Law firm Šenavičius ir partneriai RESPONSE, Associate
2019 – 2021
Ecovis ProventusLaw law firm Kvainauskas, Andziulytė ir partneriai, Associate
2018 – 2019
UADBB “Sagauta”, Associate