Information regarding bank’s target customer

Luminor offers daily banking services to citizens or residents of Estonia, Latvia, and/or Lithuania, to legal entities, registered in Estonia, and EU-based legal entities` branches, registered in Estonia, whose main planned business activity is carried out in the Baltic States and who can identify their beneficial owner, and would like to establish a business relationship with all potential customers who see Luminor bank as a partner for everyday services, as well as lending, investments, or deposits.

Our risk strategy is based on the core business principle to serve customers who predominantly are citizens or residents of Estonia, Latvia, and/or Lithuania, and customers with a strong personal or business connection to the Baltic countries. To support the strategy, we have implemented and maintain a properly functioning risk management framework which is based on the Anti-Money Laundering, Countering the Financing of Terrorism, Counter Proliferation Financing (AML/CFT/CPF) and Sanctions Risk Policy and internal standards that are defining our AML/CFT/CPF and sanctions risk appetite.

Luminor has no risk appetite for cooperation with customers, who fall under AML/CFT/CPF and sanctions laws and regulations restrictions, as well as internal AML/CFT/CFP and Sanctions Policy based absolute risk appetite limitations, for example: 

• anonymous customers; or 
• customers who concurrently conform with the following indications of shell arrangements: legal person has no connection to an actual economic activity, or the activity of a legal person forms little or no economic value, and there is no documentary information available to Luminor that would prove otherwise; the laws and regulations of the country where the legal person is registered do not impose an obligation to prepare and submit to the supervisory authorities the financial statements ; or 
• customers for whom Luminor cannot obtain full clarity and/or evidence of a reasonable economic and/or lawful purpose of its business activities or to identity the ultimate beneficial owner; 
• customers who are subjects to sanctions imposed by United Nations, European Union, or by the competent authority in the jurisdictions where Luminor operates (Estonia, Latvia, Lithuania).

We are committed to the protection of human rights, therefore we also follow sanctions imposed by United States OFAC, United Kingdom, Sweden, and Norway.

Additional information on AML/CFT/CPF and Luminor sanctions policy is available here.