LAR targets higher-risk audit firms for more intensive AML supervision

Lithuanian audit firms face more intensive anti-money-laundering supervision when their risk increasesE TAR, under a policy approved by the Lietuvos auditorių rūmai (LAR) Presidium on 31 July 2026LAR. The policy covers prevention of money laundering and terrorist financing and implementation of international sanctions.E TAR It sets out how LAR organises this supervision and does not apply to its other audit-firm oversight functions.

LAR will concentrate attention and resources on higher-risk firms, business models and services, and on firms whose suspension for compliance failures could significantly harm the public interest.E TAR Supervision becomes more intensive as a firm's risk risesE TAR and remains so until that risk falls to an acceptable levelE TAR. Lower-risk firms receive proportionately less extensive controls, focused on preventing the principal threats.

A firm's significance and risk depend on its size, its business model and that model's complexity, its links with other audit firms, and the nature of the services it provides. Potential harm to the profession's reputation and credibility, clients and the public interest also matters. Annual plans are not the only mechanism: the policy provides for unplanned inspections where needed and changes to existing plans as circumstances evolve.

For firm leaders and compliance teams, the policy makes early engagement a supervisory expectation. LAR expects firms to inform it as early as possible about existing or potential risks and problems, so these can be addressed with the least adverse impact. Responsibility for compliance rests first with the firm, including its management and those charged with governance. LAR supervision does not remove the firm's responsibility to maintain its own stability and continuity.

The approach combines supervision with guidance and consultation. Before requesting advice, a firm is expected to analyse the legislation itself; where requirements remain unclear, it should describe the uncertainty precisely and present its own view. The policy recognises that different business models may implement requirements differently, while similar activities and services presenting the same risk should receive the same requirements and supervision.

Enforcement measures are to be used only where supervisory objectives cannot be achieved otherwise, and must reflect the nature of the breach, harm and other circumstances. LAR seeks deterrent fines exceeding the income or other financial benefit gained, losses avoided or damage caused. It also envisages dialogue, agreement and, where the prevention law permits and objective reasons exist, consideration of deferring enforcement. These are policy principles, not an automatic entitlement to postponement.

The legal basis is the Lietuvos auditorių rūmų audito įmonių priežiūros pinigų plovimo ir (ar) teroristų finansavimo prevencijos srityje politika, paragraphs 3 and 8.3–8.9E TAR, approved by the LAR Presidium on 31 July 2026 by Resolution No. 1.4-46A.11.2.1E TAR under Article 4(6) of the Lietuvos Respublikos pinigų plovimo ir teroristų finansavimo prevencijos įstatymas.