Luminor has a responsibility to monitor, evaluate and observe laws and binding requirements related to financial and trade sanctions set by the UN, EU, national governments (Estonia, Latvia, Lithuania), and other authorities.
We comply with the established requirements of international sanctions imposed by:
- United Nations;
- European Union;
- countries where the bank and its affiliates are operating (Estonia, Latvia, Lithuania);
- United States of America;
- United Kingdom;
- Sweden;
- Norway;
- or any authority acting on behalf of any of them with regard to the sanctions.
Luminor is precautious when fulfilling sanctions compliance requirements, considers correspondent banks' requirements as well as its own risk appetite, and therefore, will not engage in any actions (e.g. will not execute a transaction, provide financial services, or make a deal) that directly or indirectly (through intermediaries) evade the sanctions prohibitions, correspondent banks requirements and Luminor internal decisions.
The bank may also refrain from the transaction or deal if it is not in line with our risk appetite due to high exposure to sanctions risks and heightened risk of violating sanctions laws and regulations.
According to internal policy, Luminor does not make any deals or execute transactions if they have a direct or indirect connection with the following sanctioned countries/territories:
- Iran;
- DPRK (North Korea);
- Syrian Arab Republic;
- Cuba;
- Crimea;
- non-government-controlled areas of Ukraine in the oblasts of Donetsk and Luhansk.
Luminor may suspend the provision of any services to customers located within the territories above.
Luminor may consider processing the transactions that involve these territories if their purpose is related to humanitarian aid; however, such transactions would be evaluated individually as to whether they fall under respective regulatory exceptions, require a license, etc.
Please be informed that there are international sanctions imposed on many other countries or territories, e.g., non-government-controlled areas of Kherson, Zaporizhzhia; Iraq, Sudan, etc. Therefore, the transactions involving countries falling under sanctions prohibitions may be stopped for investigation.
Luminor’s, as well as other banks’ participating in the payment chain, policy towards specific countries, areas, sectors, etc., might be more restrictive than applicable financial sanctions due to the overall financial crime and sanctions risk associated with the specific country, area, sectors, etc. Therefore, the term of executing an international transaction may be longer than usual or an international transaction may be blocked or frozen by other banks that also participate in the execution of the transaction (correspondent bank, beneficiary’s or sender’s bank).
Please note that Luminor has the responsibility and will report to the competent authorities identified subjects of sanctions as well as cases where the suspicion of transactions with sanctioned subjects or suspicion of sanctions evasion is raised in accordance with regulatory requirements. The bank has the right to cease its partnership with customers to whom sanctions apply, or if there is reasonable doubt that they are breaching or circumventing sanctions.
We consider as sanctions evasion the attempt and intentional activity to remove or conceal the involvement of sanctioned countries, territories, goods, legal entities, or natural persons in a transaction or series of transactions using various techniques that would evade financial or sectoral sanctions.
It must be noted that any attempts to perform transactions or deals related to sanctions evasion may result in severe consequences such as imprisonment, fines, or negative reputational consequences.
