Bank provides comprehensive range of banking services strictly
follows the broad range of anti-money laundering, counter terrorist financing (AML/CTF) and
Sanctions regulations in each country the group operates.
This is our commitment to do the utmost on Bank’s part that its financial services and the
transactions of its customers are compliant with the legal acts and regulations of the
European Union and are also in line with international restrictive financial sanctions
enforced by the European Union, United Nations and United States of America.
In line with the common policy in every country where Bank operates, Bank rejects any
request to execute transaction or provide financial services in breach of applicable
regulations.
Money laundering includes acts which aim to legalize money or other property acquired by way of criminal acts, or conceal its source. These acts are usually conducted by drug dealers, robbers, terrorists, burglars, tax evaders, smugglers, persons who accept bribes, and other persons related thereof. Law of the EU on the Prevention of Money Laundering and Terrorist Financing (hereinafter – AML Law) establishes the preventive measures to be taken by the banks and other subjects in order to prevent money laundering and terrorist financing.
The compliance with the requirements of Sanctions regulations, prevention of money laundering, and terrorist financing in Bank is regulated by the Procedure for Prevention on Money Laundering and Terrorist Financing.[MA1] The purpose of the procedure is to assist the employees of the Bank to duly implement in their activity the requirements of the legal acts of the EU regulating prevention of money laundering. All structural units and subsidiaries of the Bank are subject to the Procedure for Prevention on Money Laundering and Terrorist Financing.
The Bank must follow the principle "Know your customer". This implies that Bank employees have to understand the customer's activity. In order to know the customer the employee of the Bank submits Private person or Legal person questionnaires to the customer to fill in. It is necessary to receive information about customer‘s activities and income sources, financial activity. This information helps to understand customer‘s needs, it is easier to offer suitable products and services for customer. Also, implementation of principle “Know your customer” helps to prevent possible money laundering and protect customers from fraud. Also Bank must identify the actual beneficial owner, who is a natural person controlling the managing body of a legal person or a person on whose behalf and in whose interest a bank transaction is being concluded. According to AML Law, it is necessary to identify if customer or customer‘s close family members or close associates are considered as Politically Exposed Persons who are or were entrusted with prominent public functions in the European Union, international or foreign countries institutions.
If the aim of a transaction is not clear, Bank employees must inquire the customer about the aim of his financial transaction and/or the source of funds. In particular situations the Bank may request to present agreements, invoices or other documents or information confirming the customer's explanations in order to ensure transactions compliance with AML/CTF and Sanctions regulations. Until the transaction is not verified, ability to use the funds could be restricted.
The Bank protects all the information provided by a customer concerning their business relations. A customer must inform the Bank about any changes in the information provided. Throughout the entire period of business relations with a customer the Bank must verify whether the submitted data and documents are authentic and accurate as well as observe business relations with the customers.
Sanctions are set of measures imposed by the competent Sanctions Authorities against the states, natural and legal persons, as well as other subjects which violate the human rights, commit ethnically, territorial and religion conflicts, support terrorism or violate other international norms and principles. Sanctions restrictions can include requirement of asset freeze, refusing to conduct transactions, refraining from contracts with sanctioned entities / individuals, providing loans or other financing, etc.
The Bank adheres to Sanctions restrictions imposed by the following Sanctions Authorities:• Countries where the Bank and Affiliates of the Bank are operating (Estonia, Latvia, Lithuania);
• European Union;
• United Nations;
• United States of America;
• United Kingdom, or
any authority acting on behalf of any of them in connection with the Sanctions.
Bank is precautious when fulfilling Sanctions compliance requirements and rejects any request to execute transaction, provide financial services or make a deal if it can violate Sanctions restriction imposed by above stated Sanctions Authorities.
According to Internal Policy Bank is not a making any deals or executing of transactions if they have direct or indirect connection with comprehensively sanctioned countries / regions as:
• DPRK (North Korea);
• Sudan (North Sudan);
If a customer refuses to provide the Bank with the required information about the source of funds or other property (or any other additional data), the firm is forbidden to conclude a financial transaction and may terminate the deals or business relations with the customer.