For financial institutions

Bank provides comprehensive range of banking services strictly follows the broad range of anti-money laundering and counter terrorist financing (AML/CTF) 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 Republic of Lithuania and 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.

For more details on the money laundering prevension measures taken by Bank please refer to:

 General compliance statement relating to AML/CFT
Wolfsberg CBDD questionnaire

For customers

What Is Money Laundering?

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 Republic of Lithuania 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 for prevention of money laundering and terrorist financing in Bank is regulated by the Procedure for Prevention on Money Laundering and Terrorist Financing. 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 Republic of Lithuania regulating prevention of money laundering. All structural units and subsidiaries Bank are subject to the Procedure for Prevention on Money Laundering and Terrorist Financing.

Principle “Know Your Customer“

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 Republic of Lithuania, 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 or the source of funds. In particular situations the Bank may request to present agreements, invoices or other documents confirming the customer's explanations. 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.

Tax liabilities

Tax liabilities in the United States

The Government of the Republic of Lithuania has signed an agreement with the US tax authorities, called FATCA (Foreign Account Tax Compliance Act). The aim of FATCA is to target non-compliance by U.S. taxpayers using foreign accounts. Under this agreement Lithuanian financial institutions are required to identify and report aggregated amounts on accounts held by U.S. persons to the State Tax Inspectorate under the Ministry of Finance of the Republic of Lithuania, which respectively reports to the US Internal Revenue Service (IRS).

In case You need additional information please visit USA IRS homepage.

Common reporting standard (CRS)

The Common Reporting Standard (CRS) is a global reporting standard, which purpose is to solve tax evasion issues by providing information about citizens’ financial accounts in foreign countries and by introducing automatic exchange of such information between different jurisdictions. As set out in the CRS, state tax administration institutions receive information from local financial institutions and annually share it with the respective tax administration institutions in the foreign countries.

FAQ about CRS.
As the rest of the financial institutions, since 1 January 2016 we are obliged to collect data about the countries where our customers pay taxes. Therefore, we ask our new customers to provide the list of such countries and their taxpayer’s code. We will also ask our current customers who might be affected by the requirements of the CRS to provide us with the additional relevant information.

Please be reminded that the taxpayer’s code for private citizens of the Republic of Lithuania is their personal code and the taxpayer’s code for corporate customers registered in the Republic of Lithuania is the company’s registration number.

FATCA / CRS Self-Certification forms:

FATCA and CRS Self-Certification form for Entities
FATCA & CRS Self-Certification form for Individuals

If you need another form for specific FATCA purposes, you can find it on the USA IRS homepage.

In accordance with the legal requirements, we cannot offer advice on tax issues related to the CRS. In case of questions, please visit the webpage of the Organisation for Economic Co-operation and Development (OECD) or address tax specialists.

Sanctions compliance policy

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 ethnical, 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:

  • Iran;
  • DPRK (North Korea);
  • Sudan (North Sudan);
  • Syrian Arab Republic;
  • Cuba;
  • Crimea.

In Case Of Information Denied or False Information Submitted

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 Bank is forbidden to conclude a financial transaction and may terminate the deals or business relations with the customer.