Lithuania has become the European Union's leading hub for electronic money institutions, and the Bank of Lithuania has authorised a large share of the bloc's licensed EMIs. Yet holding that licence is only part of the story. A licensed EMI or fintech has its own banking need, and it is different from a merchant simply looking for an account. The firm must ring-fence client money and it must reach the payment rails. Both depend on relationships with credit institutions, and both are getting harder to secure.
Direct Answer
A Lithuania-licensed EMI needs two distinct banking relationships: safeguarding accounts at a credit institution to segregate client funds under EMD2, and correspondent or settlement banking to access payment rails. The licence permits e-money issuance; these accounts make the operation work. Correspondent access is usually the harder of the two to obtain because of de-risking pressure on smaller institutions.
This guide covers why even a fully licensed EMI must secure its own banking, why correspondent-banking access tends to be the real bottleneck, and how a strong Lithuanian licence paired with a clean AML and safeguarding framework improves the odds of getting and keeping these relationships.
Why a licensed EMI still needs its own banking
An electronic money institution licence authorises a firm to issue e-money and provide related payment services. It does not turn the firm into a bank, and it does not give it direct, unconditional access to the wider payment system. Two banking relationships fill that gap. The first is safeguarding. Under the second Electronic Money Directive, commonly cited as EMD2, an EMI must protect the funds it receives in exchange for e-money by keeping them separate from its own money. In practice that usually means holding client balances in segregated safeguarding accounts at a credit institution, so the funds are ring-fenced and identifiable if anything goes wrong with the firm.
The second relationship is settlement. To send and receive money across currencies and schemes, an EMI generally relies on correspondent or settlement banking, whether that is through direct scheme participation or an account with a bank that already holds it. Without that access the licence is largely theoretical: the firm can issue e-money on paper but struggles to move it. So the licence and the banking are complementary, not interchangeable, and a Lithuanian EMI needs to plan both from the outset rather than assume authorisation solves the problem.
Correspondent access is the real bottleneck
For many EMIs the hardest step is not obtaining the licence but keeping stable correspondent and settlement relationships. Years of de-risking have pushed some banks to withdraw from, or apply heavier scrutiny to, categories they view as higher effort or higher risk. Smaller and newer EMIs can feel this most, because a correspondent bank carries its own regulatory exposure for the clients it serves indirectly. The result is that access can be uneven, and a relationship that opens smoothly one year may be reviewed or narrowed the next.
A prudent EMI therefore treats banking as something to diversify and maintain rather than solve once. That often means more than one settlement route, clear documentation of fund flows, and a realistic picture of which sectors and geographies the firm actually serves. Concentration in a single correspondent is a genuine operational risk, because a single review can interrupt a large share of activity. Building redundancy early, while relationships are healthy, is usually easier than scrambling to replace one under pressure.
How a strong licence and clean framework improve access
A well-run Lithuanian EMI can improve its standing with banks by making itself easy to underwrite. A licence from the Bank of Lithuania signals a recognised, actively supervised regime, and that reputation tends to help when a prospective correspondent assesses the applicant. What often matters more, though, is the AML and safeguarding framework sitting behind the licence. The European Banking Authority, referenced here as the EBA, has paid close attention to how EMIs arrange and evidence safeguarding, so clear reconciliation, sound governance and demonstrable controls are not just compliance boxes but part of how a bank decides whether to take you on.
Firms extending beyond payments face an added layer. An EMI adding a crypto or MiCA-scope arm typically needs the relevant authorisation before banks will support digital-asset flows, since licensing effectively gates access to crypto-friendly banking. If that is on your roadmap, aligning the Lithuania crypto licence with your safeguarding and settlement plans early tends to prevent awkward gaps later, when a provider asks how fiat and digital assets are kept separate.
| Requirement | Safeguarding account | Correspondent / settlement account |
|---|---|---|
| Purpose | Ring-fence client funds separately from the EMI's own money, as required under EMD2 | Reach payment rails to send, receive and settle across currencies and schemes |
| Who provides it | A credit institution willing to hold segregated safeguarded balances | A bank with scheme access, or direct scheme participation where available |
| Typical difficulty | Moderate; hinges on evidencing reconciliation and controls to supervisory standards | Often the hardest step; de-risking pressure weighs most on smaller EMIs |
Final Takeaway: A Lithuanian EMI licence is the start, not the finish. Plan safeguarding and correspondent banking together, diversify settlement routes before you need to, and treat a clean, well-evidenced AML and safeguarding framework as the thing that keeps banks comfortable. Access is usually easier to protect than to rebuild.
How BankMyCapital Helps
BankMyCapital is a high-risk banking and EMI consultancy, not a bank, EMI or payment service provider, and we are not a regulated institution. We help licensed Lithuanian EMIs and fintechs map what they need, position their safeguarding and settlement requirements to the right archetype of provider, and prepare the documentation that correspondent banks expect to see. Our banking service engagements start from 1,500 EUR, with a separate EMI onboarding fee where an introduction proceeds. We guide the process and improve your odds; we do not provide accounts or make regulatory guarantees on any provider's behalf.