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Lithuania screens foreign investment in objects of importance to national security under the Law on the Protection of Objects of Importance to Ensuring National Security (NSU Act, Law No. IX-1132), administered by the Commission for the Coordination of Protection of Objects of Importance to National Security (the Commission). Transactions — acquisitions of ownership, control, or significant influence — in qualifying entities require pre-notification and, in sensitive cases, Commission approval. The list of strategically important economic activities that triggers the regime is maintained by a combination of the NSU Act itself and Government resolutions.
Scope expansion to crypto-assets and MiCA-aligned instruments. Law XIV-2985 adds to the NSU Act's list of strategically important economic activities the following MiCA-defined categories:
The addition explicitly cross-references EU Regulation 2023/1114 (MiCA), making Lithuania one of the first EU Member States to anchor crypto-financial activity within a formal national-security FDI screening perimeter rather than relying solely on financial-stability (ESMA/EBA) oversight. A non-EU investor acquiring or expanding influence over a Lithuanian e-money institution, ART issuer, or licensed CASP must now notify and, depending on the sensitivity assessment, seek Commission clearance.
Definitional refinements. The amendments tighten three concepts: 1. Persons acting in concert — clarifies aggregation rules for coordinated voting-block analysis, closing a gap where dispersed but coordinated acquirers could fall below per-party screening thresholds. 2. Controlling person — aligns the definition with post-2022 beneficial-ownership disclosure standards and indirect-control mapping, consistent with the EU Reg 2019/452 cooperation-mechanism requirements. 3. Manager of critical information infrastructure — clarifies which entities administering networked digital infrastructure are within scope of the NSU Act's management-change notification obligations.
Interaction with the October 2024 NIS2/Cyber-Security Law package. The XIV-2985 amendments are part of a wider 18 October 2024 legislative package that simultaneously synchronised the NSU Act with Lithuania's new Cyber-Security Law transposing the EU NIS2 Directive (Directive (EU) 2022/2555). That parallel instrument updates the definition of critical information infrastructure managers and establishes inter- agency reporting lines between the National Cyber Security Centre (NKSC) and the Commission screening body.
Government Resolution No. 978 (13 November 2024). A subsequent Government resolution updated the enumerated list of economic activities considered strategically important for national security, operationalising the XIV-2985 scope expansion at the implementing-regulation level and specifying the CASP licensing categories drawn from MiCA Title V.
Why severity = 3. The law makes a targeted but meaningful scope expansion: first-in-class inclusion of MiCA-defined crypto-asset services in a national-security FDI screening regime is a structural first in the EU Member State cohort and sets a template for peers. However, the amendment does not introduce new blocking powers, retroactive-review authority, or cross-border-financing triggers of the kind found in the Latvia 2024 amendments (severity 4), nor does it constitute a foundational horizontal statute. The crypto-asset additions are incremental relative to the existing NSU Act perimeter and the practical transaction volume in Lithuanian CASP acquisitions is modest. Severity 3 (moderate: meaningful perimeter extension; meaningful for digital-asset M&A structuring but not macroeconomically systemically large).
FDI screening cluster: EE (VUHS Act 2023), LV (National Security Law amendments 2024), and now LT form a hardened Baltic screening perimeter with coordinated inbound-FDI review under EU Reg 2019/452.
inside a national-security FDI perimeter is structurally novel: it means the acquisition or effective control of a MiCA-licensed entity in Lithuania by a non-EU investor is now dual-regulated — financial licence transfer rules (ESMA/EBA passporting) AND national-security pre-notification. This creates compliance friction for non-EU digital- asset acquirers entering the EU through the Baltic gateway.
2985 is part of a post-2022 EU Member State cohort implementing or upgrading horizontal FDI screening (EE VUHS 2023, LV NSU amendments 2024, BG Investment Promotion Act 2024, HR Act 136/2025, SI ZSInv-C 2023) in response to Russian-aggression threat-elevation and the EU 2019/452 cooperation framework maturation.
Lithuanian-licensed CASP, EMT issuer, or ART issuer post-October 2024 must map this NSU Act notification requirement onto deal timelines.
list has not been confirmed in full English text; its exact CASP category enumeration should be verified via the e-tar.lt consolidated register before any compliance determination.
notification obligation for changes-of-control completed before 18 October 2024 but not yet finalised — the Commission has not published a formal transitional guidance note.
(December 2025 political agreement) and mandatory-screening threshold alignment remains to be clarified in the next NSU Act update cycle.