RE: GS Fintech UAB share capital15 Mar 2026 20:16
As of March 15, 2026, there is no public confirmation that GS Fintech UAB is fully compliant with DORA or AMLA standards — and in fact, the absence of a granted MiCA CASP license strongly suggests they are not yet fully compliant with the integrated requirements these regulations impose on crypto-asset service providers (CASPs).
Key Reasons and Current Status
MiCA License Status — GS Fintech UAB (the Lithuanian subsidiary of GSTechnologies Ltd) did not receive full MiCA CASP authorisation by the end of the transitional period on 31 December 2025, despite submitting an application in September 2025. The company announced plans to resubmit in Q1 2026 (i.e., January–March 2026).
As of mid-March 2026, no public announcements, RNS updates from GSTechnologies, or Bank of Lithuania (BoL) registry entries indicate approval has been granted. Lithuania's MiCA rollout has been extremely strict — only a handful (e.g., ~3 reported in early 2026) full CASP licenses issued overall, with hundreds of legacy VASPs exiting or failing to transition.
DORA Integration
DORA (fully applicable since 17 January 2025) is a core prerequisite embedded in the MiCA authorisation process for CASPs. It requires demonstrable ICT/cyber resilience, including risk frameworks, mandatory incident reporting (e.g., 4-hour notifications), third-party oversight (cloud/ICT providers), resilience testing, and often independent audits.
Since the initial application was not approved by the BoL (and resubmission is ongoing/pending), it's reasonable to infer that GS Fintech has not yet satisfied the BoL's DORA-related evidence requirements. No company statements claim full DORA compliance independently of the MiCA process.
AMLA and AML/CTF Standards
AMLA (operational in Frankfurt since mid-2025) coordinates and influences EU AML supervision under the new Single Rulebook, but national authorities (like BoL) handle CASP licensing. MiCA demands "day-one" readiness for automated AML systems, Travel Rule compliance (for crypto transfers), enhanced KYC/sanctions screening, and effective monitoring — all aligned with AMLA expectations.
Again, no public evidence shows GS Fintech has achieved this level. The BoL has revoked licenses from other fintechs in early 2026 for systematic AML/governance failures (e.g., cases like Paytend Europe), underscoring high scrutiny.
Bake legacy integration (post-2025 acquisition) likely involved AML/KYC upgrades for a large user base, but nothing confirms these cleared regulatory hurdles for authorisation.
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