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Virtual currency transactions: the court held that trading in gift cards paid for with cryptocurrency is equivalent to virtual currency transactions and therefore subject to the requirements of the Law on the Prevention of Money Laundering and Terrorist Financing.

By a ruling of 19 November 2025, the Supreme Administrative Court of Lithuania dismissed the appeal lodged by UAB Decentralized and upheld the judgment of the Regional Administrative Court. That judgment confirmed that the Financial Crime Investigation Service had lawfully imposed a fine of EUR 16,530 on the company for breaches of the Law on the Prevention of Money Laundering and Terrorist Financing.

The case established that the company traded gift cards issued by various service and goods providers (such as Amazon, Walmart, eBay and BinancePay), which customers purchased using virtual currency. The gift cards were subsequently used to pay for selected services or goods and, in the Court’s assessment, effectively functioned as prepaid payment instruments. Under the Law on the Prevention of Money Laundering and Terrorist Financing and European Union legislation, such activity constitutes virtual currency transactions and is therefore subject to anti-money laundering requirements.

The applicant disagreed with this assessment, arguing that trading in gift cards did not amount to the activities of a virtual currency exchange operator and should therefore not be regulated under the Law on the Prevention of Money Laundering and Terrorist Financing. However, the Supreme Administrative Court of Lithuania noted that the legislature sought to encompass all forms of virtual currency use, and that the gift card purchase and sale model fell within that scope both in terms of its operational mechanism and its risk profile. Consequently, by engaging in such activity, the company was required to apply customer and transaction due diligence, risk assessment measures and other obligations laid down in the Law.

The Court also held that the company had unjustifiably sought to have the infringement relating to the failure to notify the Financial Crime Investigation Service of the appointment of a designated responsible employee classified as a minor violation. Under the law, such information must be submitted within seven working days; however, UAB Decentralized complied with this obligation only after more than one year. The Court stated that, in such circumstances, the infringement could not be regarded as minor, as it directly affected the effective functioning of the anti-money laundering system.

The panel of judges emphasised that the decision of the Financial Crime Investigation Service was comprehensive, clearly reasoned, adopted within its competence and in accordance with the applicable legal framework. The amount of the fine was determined having regard to the nature, scale and duration of the infringements, as well as the company’s financial situation, and was not disproportionate.

Having regard to all the circumstances established in the case, the Supreme Administrative Court of Lithuania dismissed the appeal lodged by UAB Decentralized and upheld the decision of the Financial Crime Investigation Service imposing the fine.

Administrative case No eA-1158-415/2025