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Financial supervision: in the context of the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, each systematic infringement may be sanctioned separately, provided that the overall penalties remain effective and proportionate

In its judgment of 10 March 2026, the Supreme Administrative Court of Lithuania (SACL), sitting in an extended formation, held that the Bank of Lithuania lawfully imposed eight separate fines on an electronic money institution for breaches of anti-money laundering and counter-terrorist financing requirements.

The case concerned a decision of the Bank of Lithuania finding that the applicant had committed eight infringements of the Law on the Prevention of Money Laundering and Terrorist Financing. The court of first instance had annulled two of those findings and significantly reduced the overall fine.

In resolving the dispute, SACL relied on the preliminary ruling of the Court of Justice of the European Union (CJEU) delivered in case Lietuvos bankas, C-671/23, following a request for a preliminary ruling made by SACL. The CJEU clarified that EU law does not preclude national rules or practices under which each ‘systematic infringement’ identified during a single inspection may be treated as a ‘separate systematic infringement’ giving rise to a separate fine, in so far as the general principles of EU law are observed, in particular the principles of effectiveness and proportionality.

Applying that interpretation, SACL held that the Bank of Lithuania had correctly identified all eight infringements and was entitled to impose separate sanctions for each of them. The Court emphasised that supervisory authorities must ensure that penalties are proportionate overall, taking into account the specific circumstances of the case and the financial situation of the undertaking concerned.

The Court further noted that, in the present case, the Bank of Lithuania had duly individualised the sanctions and adjusted their amount, inter alia by reducing the baseline level of the fines in view of their potential disproportionality in relation to the undertaking’s annual revenue.

Administrative case No. eA-1-822/2026