Opening a company bank account in Lithuania: what the bank asks for

A company can open an account with a bank or with an electronic money institution, and both must identify and verify the identity of the customer and of the beneficial owner before starting a business relationship (Article 9(1)(1) of the Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania, PPTFPĮ). Opening a bank account for a company starts with the company’s documents: its name, legal form, registered office and the address where it actually operates, its code and its register extract (PPTFPĮ Article 10(2)). The bank will also ask for details of the manager and of the representative (PPTFPĮ Article 10(3)) and for information on why you are opening the account and what transactions you expect (PPTFPĮ Article 9(14)). If you do not provide this information, or it is not sufficient, the financial institution is prohibited from establishing a business relationship (PPTFPĮ Article 9(18)). When a UAB is being formed, the founders pay the initial contributions for the shares into the company’s accumulation account (kaupiamoji sąskaita) (Article 8(4) of the Law on Companies of the Republic of Lithuania, ABĮ), which may be opened with a credit or an electronic money institution (ABĮ Article 7(5) and (7)).

If a shareholder or the manager of the company is a foreigner, we explain what changes in the article “Foreign-owned UAB: bank account, identification and documents”. Here we cover the general rules that apply to every company.

Where a company can open an account

The law places the identification duties on financial institutions. These are not only credit institutions (banks) but also payment institutions and electronic money institutions (PPTFPĮ Article 2(7)). So at a bank and at an electronic money institution a company provides essentially the same information, and the institution checks it under the same PPTFPĮ rules.

While a UAB is still being formed, the memorandum of association or the deed of incorporation gives the right to open an accumulation account for the company being formed with a credit or electronic money institution (ABĮ Article 7(5) and (7)). The initial contributions for the shares are paid into it within the period set in the incorporation document. The funds in the accumulation account may be used only after the company is registered (ABĮ Article 8(4)). So the accumulation account serves to collect the initial contributions, and the company may use its funds only once it is registered.

How the formation itself works and who signs the documents is covered in the article “Setting up a UAB step by step: documents, signatures and the notary”.

Opening a bank account for a company: which documents you need

When identifying a legal person, the financial institution requires its identity documents or copies of them certified by a notary. They must show (PPTFPĮ Article 10(2)):

• the name;
• the legal form, the registered office (address) and the address where the business is actually carried on;
• the code, if one has been assigned;
• the register extract and its date of issue.

A company is represented by a natural person, so that person is identified as a natural person. In addition, the customer provides details of the legal person’s manager: first name, surname, personal code and citizenship (PPTFPĮ Article 10(3)).

The financial institution has the right to obtain the necessary data itself from state registers and information systems. It may then not require you to provide them, if you confirm the data obtained from the registers with your signature; where the data come from Lithuanian or other EU registers, the institution may also waive the signature (PPTFPĮ Article 10(4)).

Where a natural person represents the company, the financial institution must require that person’s power of attorney and check whether the person who issued it had the right to issue it, how long it is valid and which actions it authorises. A power of attorney issued abroad must be legalised or certified with an apostille, except powers of attorney issued in EU Member States (PPTFPĮ Article 10(5)).

A financial institution is prohibited from opening an account without requiring the data confirming the customer’s identity, or where there is a reasonable suspicion that the data in the documents are false or forged (PPTFPĮ Article 9(21)).

What the bank asks about the business and the owners

Documents are not enough. Each time it identifies a customer, the financial institution must:

• establish whether the customer acts on its own behalf or is controlled, and identify the beneficial owner (PPTFPĮ Article 9(12));
• take reasonable measures to understand the ownership and control structure of a legal person and the nature of its business (PPTFPĮ Article 9(13));
• obtain from the customer information on the purpose and intended nature of the business relationship (PPTFPĮ Article 9(14));
• verify the data on the basis of documents or information from a reliable and independent source (PPTFPĮ Article 9(15)).

It is therefore worth describing in advance what the company does or will do, whom it will deal with and where its funds will come from. Once the account is open, the financial institution must monitor the business relationship on an ongoing basis and check that the transactions match what it knows about the customer, its business, its risk profile and the source of funds (PPTFPĮ Article 9(16)). So what you state when opening the account is later compared with the actual transactions.

The law also allows an exception. If the financial institution’s risk assessment and management procedures establish a low money laundering and terrorist financing risk, it may open an account before verifying the identity, but only once it has received the basic data of the company, its representative and the beneficial owner. However, no transactions are carried out in such an account until identification is completed, and identification must be finalised no later than one month after the account is opened (PPTFPĮ Article 9(5)).

Do you have to visit the bank

Not necessarily. The identity of the company’s representative and of the beneficial owner may also be established without the person being physically present, but only in the ways listed in the law: for example, with an electronic identification means issued in the EU at a high or substantial assurance level, a qualified electronic signature or live video transmission (PPTFPĮ Article 11(1)). Whether a given financial institution uses these methods is its own decision. How long registration takes and whether the founder needs to travel is covered in the article “UAB incorporation: registration time and whether you need to travel to Lithuania”.

What to do if the bank refuses to open an account

A financial institution is prohibited from establishing or continuing a business relationship when it cannot meet the identification requirements. This is the case where the customer does not provide data confirming its identity, provides incomplete or incorrect data, avoids providing information on the beneficial owner, or the data provided are not sufficient (PPTFPĮ Article 9(18)). If the customer avoids or refuses to provide additional information within the period set by the financial institution, it may refuse to carry out transactions or terminate the business relationship (PPTFPĮ Article 18). A financial institution that did not carry out the customer’s transactions for the reasons set out in PPTFPĮ Article 9(18) is not liable to the customer for non-performance of contractual obligations or for damage (PPTFPĮ Article 9(24)).

These provisions are not a free-standing ground to turn a customer away. In its ruling of 5 November 2024 in civil case No. e3K-3-206-611/2024 the Supreme Court of Lithuania decided a dispute between a natural person and a bank over the termination of an existing bank account contract. The court held that a bank account contract is a public contract and a credit institution must conclude a framework contract with every person who applies, except in cases set out in other laws, for example the PPTFPĮ (paragraphs 27 and 30). PPTFPĮ Article 9(18) may not be interpreted broadly, and terminating a business relationship is an extreme measure that must be proportionate to the money laundering and terrorist financing risk the customer poses (paragraph 40). Under PPTFPĮ Article 18 the bank must first request additional information (paragraph 41), and when terminating the contract it must give the customer its reasons (paragraph 50), except information that has been passed to the Financial Crime Investigation Service (paragraph 53).

So first find out which information was missing and provide it: contracts with customers or suppliers, a business plan, documents showing where the funds come from, the ownership chart up to the natural persons. If one institution does not open the account, you can approach another bank or electronic money institution; they are all financial institutions (PPTFPĮ Article 2(7)), so they will need the same information.

What changes from 2027

The PPTFPĮ version in force from 1 January 2027 does not change Articles 9, 10, 11 and 18 discussed here. From 10 July 2027 the EU anti-money laundering regulation will apply (Article 90 of Regulation (EU) 2024/1624). It is directly applicable in all Member States, so from then on the customer identification requirements will also follow from this regulation, not only from the PPTFPĮ.

More on setting up a company

• Establishment of legal entities: service page
• Foreign-owned UAB: bank account, identification and documents
• Setting up a UAB step by step: documents, signatures and the notary
• UAB incorporation: registration time and whether you need to travel to Lithuania

How to start

Send us the company’s register extract, a short description of the business, the ownership chart up to the natural persons and, if a bank has already refused, its reply. We will help prepare the documents for the financial institution and, if needed, a power of attorney for the representative.

Phone +370 5 212 1506, email info@linden.lt

More about this service: Establishment of legal entities.