Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.
What Lithuania actually says
Lithuania took the same route as Estonia and reached a similar destination by a different instrument. Rather than testing substance and ownership, it raised the capital floor to EUR 125,000 and struck off everyone who had not met it by the end of 2022. Firms lost the right to operate from the first day of 2023. Like Estonia's, this was a filter on who may hold a licence rather than a rule about confidentiality, and we located nothing in Lithuanian law addressing anonymity-enhancing assets or self-hosted wallets. Supervision now sits with the central bank, which is a slightly unusual choice among member states.
The instruments that matter
- EUR 125,000 minimum capital
- introduced by a law in force from November 2022, a large step up from the previous position
- Non-compliant firms struck off
- operators that had not met the new requirements by 31 December 2022 were removed from the register of exchange and wallet operators and lost the right to provide services from 1 January 2023
- Supervision moved to the central bank
- the Bank of Lithuania is the competent authority for crypto-asset service providers under the European regime
- No located rule on confidentiality
- we found no Lithuanian instrument restricting anonymity-enhancing assets or transfers to self-hosted wallets
What this means for confidential transactions
Bubble is built for exactly this shape of obligation: amounts and balances live on chain as ciphertexts, computation happens without decryption, and the only disclosure path is an on-chain access list through which an authorized party - an auditor, a supervisor, a counterparty - can request scoped decryption. That is confidentiality from the public, not from the regulator.
Related entries
- CzechiaEurope · EU baseline, supervised by the central bank
- EstoniaEurope · The licence cull that reshaped the European market
- AustriaEurope · EU baseline, with an early transition close
- BelgiumEurope · EU baseline, with no national layer on confidentiality
- DenmarkEurope · EU baseline, with tax as the historic pressure point
- FranceEurope · Hardest against anonymity, most literate about privacy tech
Compliant by default.
See how selective disclosure satisfies a supervisor without publishing your book to the world.