Lithuanian audit firms face restated AML inspection rulebook

Audit firms operating in Lithuania, including auditors who practise independently, are subject to a restated inspection rulebook for anti-money-laundering and counter-terrorist-financing (AML/CFT) complianceE TAR. The presidium of the Lithuanian Chamber of Auditors (Lietuvos auditorių rūmai, LAR) adopted decision No 1.4-57.14.9.1E TAR on 14 September 2026E TAR, restating in a new wording the procedure first approved on 20 February 2024E TAR (No 1.4-9.2.15.1) that governs how LAR plans, staffs, conducts and decides AML/CFT inspections of audit firms. The procedure implements Article 4(6) of the Lietuvos Respublikos pinigų plovimo ir teroristų finansavimo prevencijos įstatymasE TAR.

The Quality Control Committee approves the annual inspection plan each year by 31 MayE TAR, directing scrutiny at the highest-risk cases. Risk inputs include the latest European Commission and national money-laundering risk assessments, foreign and international bodies' risk information, firms' annual AML reports, client numbers and risk, service risk, client country or geographic risk, suspicious-transaction reporting, cash-transaction reports at or above EUR 15,000, internal risk-assessment and control procedures, designated AML staff, prior inspection results, timely filing of the annual AML report, and other factors such as compliance history. A firm enters the plan when the committee rates it risky and it has not been inspected for more than three years, or when it failed to file the prior-period annual AML reportE TAR.

LAR notifies selected firms of the inspection period and the appointed inspector within five working days of approving or amending the plan, and publishes the approved plan on its website. A firm has 15 working days from receipt to accept or object to the inspector or the period, giving reasonsE TAR, and the committee may appoint another inspector or change the period.

Inspectors are auditor-controllers or other persons the presidium approves for three-year terms. Other appointees must have at least three years of AML risk-management experience or a recognised certificate or higher-education diploma in the field, plus at least eight hours of AML training each year. Within 15 working days of plan approval they confirm in writing the absence of conflicts and pledge independence. An inspector is not independent where family, close-kinship or affinity ties, recent employment, board membership or shareholding (ended less than three years ago), significant business ties (ended less than a year ago), or other material conditions link them to the firm.

During inspections, inspectors may take oral or written explanations, summon persons to LAR premises, use technical means, and obtain data and documents from other businesses and from state or municipal bodies; these demands are binding, with non-compliance attracting the measures in Article 36(1)(1)-(6) of the Įstatymas. Inspections take place on the firm's premises, or at LAR premises or remotely where agreed five working days in advance. The inspector completes the inspection report and questionnaire within 15 working days, the firm's head may respond within 14 working days, and the inspector files everything with LAR within 14 days after that window.

Where deficiencies or violations are found, the committee may propose that the presidium issue a binding instruction under Article 35, impose measures under Article 36(1)(1)-(6) following Article 37, order an additional inspection, or impose no measure under Article 38E TAR. Before ordering instructions or measures, the presidium gives the firm 14 working days to submit explanations; neither silence nor a duly notified firm's absence blocks a decision, and imposed measures are published under Article 41. Firms may appeal presidium decisions under Article 47 and related legislation. Legal basis: Lietuvos auditorių rūmų prezidiumo 2026 m. rugsėjo 14 d. nutarimas Nr. 1.4-57.14.9.1 and Lietuvos Respublikos pinigų plovimo ir teroristų finansavimo prevencijos įstatymas.