Your one-stop-shop for global payments

License granted & start of operations

• The Bank of Lithuania issues Wallter’s Electronic Money Institution (EMI) Licence and the company starts operations with 2 employees.

Development of services

• Wallter team is increasing and local organization starts providing better payments solutions to clients. The Board approves Money laundering and terrorist financing prevention policy and the Compliance department grows up to 4 compliance officers.

Managing operational risks

• Compliance and operational risk management are the main focus of Wallter. The Board approves detailed new procedures, policies and also updates for existing ones: guides on Transaction monitoring desk reference and Onboarding desk reference, update for Procedure for clients’ risk assessment, a new version of Money laundering and terrorist financing prevention policy, a new procedure for KYC refresh, new Suspicious transaction escalation procedure.
• Wallter forms a Committee on risk and compliance.
• Wallter performs a Company-Wide Risk Assessment.
• Deloitte is contracted to audit Wallter results for the year 2019 and findings are fully implemented into Wallter’s compliance procedures.

Strategic decision to lower risk appetite

• The management team adopts a strategic decision to lower risk acceptance and clients’ portfolio starts to change, the low-risk portfolio is increasing, while the number of risky clients constantly decreases.

New top management & growth of compliance team

• Wallter appoints a new internal auditor and new top management, CCO and Country manager, who starts a company-wide renewal and systematic compliance revision.
• Compliance department continues to grow from 7 professionals in January to 18 people in June, with a confirmed target to reach 25 employees by the end of 2021 – a new head of risk management department is appointed in March 2021.
• The Board approves The Open source check and Retrospective transaction monitoring policies which define procedures on the usage of external open source data for clients’ risks assessment and monitoring transactions retrospectively, also evaluating client risks.
• The Bank of Lithuania publishes a market report, showing Wallter as 3rd largest EMI in Lithuania with an 8.3% market share of the total income of all 80 EMI licensed in the country.

Updating service quality & risk management system

• The Board approves a new management approach, that processes development and sets risk mitigation as a constant task for all major departments.

• Starts an internal reform to update service quality and risk management processes.

• Major areas for improvement – client risk data management, operational risk management, strengthening remote customer identification, internal rules and procedures, growing internal functional teams.

• In cooperation with a third party, Wallter provides more attention to retrospective transaction analysis.

• A new automated risk evaluation system has started its operation.

• In June – July, the Board approves a new policy on customer onboarding procedure and new risk calculation rules. Also, approves two plans: one for seminars and competence building on money laundering and financing of terrorism and the second to strengthen its transaction monitoring procedures and AI tools dedicated to transaction monitoring. Moreover, it is appointed a new Board member responsible for AML/TF risk mitigation measures.

Internal and external audits for improvement of the compliance framework

• Internal GDPR project and appointment of external Data Protection Officer (DPO)
• Anti-Money Laundering (AML) audit by PwC for 2021
• Customers risk revaluation
• Additional investments in the field of money laundering (ML) and terrorism financing (TF) prevention
• Internal audit report for the year 2020
• Additional trainings were organized for Wallter’s employees in the field of ML/TF prevention
• Introduction of a quality control process in the process of various compliance processes.

Creation of new procedures and implementation audit findings

• Strengthening retrospective monitoring of transactions
• Sanctions screening process improvements and audit
• Crypto trainings for Wallter employees
• Compliance Committee has been formed and changed Risk and Compliance Committee
• The number of employees of the Compliance Department has been increased, and their qualifications have been raised in various internal and external trainings
• Quality assurance of remote identification services provided by UAB iDenfy
• Quality assurance of prepaid card provider CreditCo, UAB
• Enhanced monitoring of card payment transactions
• Process improvements for ongoing client information updates
• Implementation of a new transaction monitoring and automated risk calculator tool i-Spiral
• New risk scoring procedure.

Process improvements

• UK trademark registration
• New services – card processing in partnership with World-Card.com
• Implementation of a new transaction monitoring tool i-Spiral
• Management changes (new Board Members and Deputy CEO)
• GDPR audit
• Audit and improvements to sanctions screening tools
• Starting AEMI licensing in the UK
• Improvements to internal compliance procedures.

Strengthening ICT and cyber security areas

• Developing ICT and cyber security areas and appointment of external Chief Information Security Officer (CISO)
• Upgrade to new sanctions screening tool of LexisNexis
• External AML/CTF ICS audit for 2022
• Raising awareness of employees and clients of Phishing Scams
• Conducting regular security audits and penetration testing
• Updated Risk Management Procedure and EWRA approved
• MLRO report for 2022
• Annual review of client base and portfolio

Improvements on onboarding process and compliance with AML/CTF requirements

• Strengthening Internal Audit function
• Approval of Wallter Risk Management Strategy
• Updates on Wallter Client Onboarding desk reference guide
• Additional implementations on address screening measures
• Improvements on Client Information Form and onboarding process
• Development of automated risk calculator tool i-Spiral
• Internal knowledge sharing sessions of onboarding and transaction monitoring processes
• GDPR Awareness Training and Introduction to DORA and NIS2
• Risk Management Risk Training

Improvements on transaction monitoring process

• Development of transaction monitoring process
• Efficiency and effectiveness testing of transaction monitoring rules
• Outsourcing new AML/sanctions screening tool GlobalPass
• Approval of Business Continuity Plan and Disaster Recovery Plan
• Performed Internal Audits on internal processes
• Implementation of additional fraud prevention measures
• Improvements of the provision of payment services and the experience of payment service users

Improvements in internal control

• MLRO and CCO report for 2023
• Management changes (new Management Board member responsible for organization and implementation of measures for AML/CTF).
• Implementation of a new RiskNarrative tool provided by LexisNexis Risk Solutions (Europe) Limited
• Performed internal audits on internal processes and external AML/CTF audit for 2023
• Appointment of Fraud Prevention Officer
• Conducting regular security audits and penetration testing
• Implemented process to ensure timely update of internal documents and procedures
• Conducted trainings on risk management, information security, GDPR, Suspicious Transaction&Activity Escalation training, etc.
• Implementation of enhanced due diligence requirements for VASPs/CASPs according to MiCA regulation.