Under the national and international legal acts governing the prevention of money laundering and terrorist financing, we must implement the principle of "Know Your Customer". Therefore, before entering into a business relationship with a customer, we ask them to fill out the "Know Your Customer" questionnaire, then update it on a regular basis. We notify our customers about the approaching deadline via the internet bank, email, and/or SMS message.

Collecting up‑to‑date information about customers allows us to identify and prevent suspicious operations on their accounts, as well as protect their funds.

Yes, a minor can also fill out the questionnaire. If a young person is under the age of 14, one of the parents, step‑parents, or guardians needs to fill out and sign the questionnaire. If a young person is between the age of 14 and 18 and has the consent of one of their parents or other legal representatives to independently and at their discretion dispose of funds in the account(s), they themselves can fill out and sign the questionnaire.

You can update your information:

1. In the internet bank

• Update your information in the Internet bank by selecting: Settings → Client Questionnaire.
• Update your company‘s information in the Internet bank by selecting: Applications → New application → Other services → Legal entity questionnaire.

2. Fill out the questionnaire and send it to us by registered post or email. 

Download the questionnaire:

• you can find the Natural Person‘s Questionnaire here.
• the Legal Entity‘s Questionnaire here.

Fill out the Questionnaire and send it by registered post to Luminor Bank AS Lithuanian Branch, Konstitucijos pr. 21A, 03601, Vilnius, Lithuania, or by email to klientoanketa@luminor.lt. When you send the form by post, please scan it (if you sign it by hand) or confirm it with an electronic signature.

Please note that only the head of the company can fill out and sign the Legal Entity‘s Questionnaire.

3. Call us

If you are a natural person, you can update your information over the phone. Please call us at +370 5 239 3444 (from 8AMto 6PM). If you are a Private Banking customer, please contact your Private Banker. 

Your representative can fill out the Customer Questionnaire if they provide us with a valid representation document of the appropriate form and content (e.g. a notarised Power of Attorney). Representation documents issued in foreign countries must be legalised or certified with an apostille, except for foreign countries where official documents do not need to be legalised or certified with an apostille according to valid international agreements between Lithuania and foreign countries. The list of foreign countries with Lithuania has concluded such agreements is provided on the website of the Ministry of Foreign Affairs of the Republic of Lithuania at keliauk.urm.lt/en under the "Consular services" section. 

Legislation establishing strict customer identification requirements also provides for actions that banks can take if their customers avoid or refuse to submit the Client Questionnaire within the specified deadlines. No restrictions are applied if the information is updated on time and properly.

Under the Law of the Republic of Lithuania on the Prevention of Money Laundering and Terrorist Financing, we are required to collect information about politically exposed (vulnerable) persons. A politically exposed (vulnerable) person is a natural person who currently holds, or has held within the last 12 months, an important public position in any state and/or in any international or foreign state institution. His/her close family members (spouse, person with whom a registered partnership is concluded (hereinafter – cohabitant), parents, brothers, sisters, children, spouses of children, cohabitants of children) or his/her close associates (a natural person who is a participant of the same legal entity or an organization without legal entity status as the person holding important public positions or who maintains other business relationships; a natural person who is the sole beneficiary of a legal entity or an organization without legal entity status, established or operating de facto to achieve financial or another personal benefit to the person holding important public positions). When deciding whether a relative is a politically exposed (vulnerable) person, we to follow the concept of a close family member established in the aforementioned and other legal acts, as only these close family members are considered to be politically exposed (vulnerable) persons. We are required to collect information about politically exposed (vulnerable) persons by the Law of the Republic of Lithuania on the Prevention of Money Laundering and  Terrorists Financing. 

Prominent public functions mean any of the following public functions: 

• head of state, head of government, minister, deputy minister or assistant minister, state secretary, member of parliament, chancellor of government or ministry;
• member of parliament;
• member of courts, constitutional courts, or of other high‑level judicial bodies whose decisions cannot be appealed;
• mayor of the municipality, director of municipal administration;
• member of the governing body of the national  supreme audit and control institution or chair, deputy chair or member of the board of a central bank;
• ambassador, chargé d'affaires, the Commander of the Lithuanian Armed Forces, commanders of military units and formation, Chief of Defence Staff, or high‑ranking military officer from foreign armed forces;
• member of the management or supervisory board of state‑owned enterprises, joint‑stock companies, or closed joint‑stock companies, of which the shares or a portion of shares granting more than half of all votes at the general meeting of shareholders of these companies belong to the state by ownership right, management or supervision;
• member of the management or supervisory body of a municipal enterprise, joint‑stock company, or private limited company, of which shares or a portion of shares granting more than half of all votes in the general shareholders' meeting are owned by the municipality, and which are considered as large companies under the Law of the Republic of Lithuania on Financial Reporting by Undertakings;
• head of an international intergovernmental organization, its deputy head, or a member of its governing or supervisory body;
• deputy leader of the political party, and member of the party's governing body.

Please note that if you are a family member or a close associate of a politically exposed (affected) person, you must provide the requested information about the mentioned personell. The status of a politically exposed (affected) person or a relationship with such a person does not mean that the bank account will not be opened or that the access to banking services will be restricted. This means that we will have to perform additional procedures required by law.

The Customer questionnaire is the first step in getting to know our customers better and obtaining information required by law. Supervisory institutions and laws require us to know to whom we provide our services. Providing information about the income received helps to better understand the origin of funds in the client's account and whether financial operations correspond to the income received. This helps us to know our customers better and to ensure the safety of their funds.

The Law of the Republic of Lithuania on the Prevention of Money Laundering and Terrorist Financing obliges us to collect information about the nature, purpose, and origin of the business relationship with the customer. The workplace and the nature of duties are an integral part of this information

A business activity code (EVRK in Lithuanian or NACE in French) is a classifier of economic activities. It consists of six characters. the first four (sections, groups, and classes of economic activities) are the same in all European countries, and the remaining characters are national subgroups. EVRK allows all economic subjects in the country to be classified by the category of activity, which is important for managing economic statistics, registering companies and regulating their activities, issuing business licenses, and setting occupational safety and health requirements. More information about EVRK codes can be found here. To check the company's EVRK code/activity please click here.

We need this information to understand the customer‘s activity, and the nature of financial operations, and to predict possible future financial behavior. This data allows us to understand which financial operations are typical for the customer, and which may be identified as unusual. This way, we can prevent possible financial crimes and the loss of the  funds. If the planned turnover significantly differs from the actual turnover, we may ask some additional questions and request the customer to update information in the Customer‘s questionnaire. Please note that this information collection is not related to the transaction limits set for you.

According to Article 9(18) of the Law on the Prevention of Money Laundering and Terrorist Financing, the bank is prohibited from carrying out transactions, establishing or continuing business relationships with a customer who does not provide information about the origin of funds (assets), the nature of transactions, business relationships with counterparties, information about the company's management structure and the actual beneficiaries or other relevant information, provides incomplete information, or the information is incorrect. The same article of the law states that in cases where the customer avoids or refuses to provide additional information requested by the bank within the given timeframe, the bank refuse to perform financial operations or transactions, terminate agreements or business relationships.

Pursuant to the Law on the Prevention of Money Laundering and Terrorist Financing and in accordance with the principle "Know Your Customer," we can only provide services to the customers/their representatives if their identity has been properly verified. Therefore, it is necessary to provide a copy of the submitted identity document, including the person's photo and information.

Before establishing any business relationships, we need to understand the purpose of the account opening, identify the source of income, and the nature of the planned operations. In certain cases, when information is incomplete, we may request to provide employment contracts, agreements with the partners, and documents provide the address of residence (or address of actual activity).

• The direct owner, i.e a natural person who directly controls a legal entity by owning more than 25% of its shares or voting rights
• The indirect owner, i.e. a natural person who controls a legal entity(1) that holds more than 25% of the shares or voting rights of another legal entity(2) and thus indirectly controls the latter legal entity;
• A natural person who otherwise controls a legal entity, for example, has the right to appoint or dismiss the legal entity's manager, make strategic decisions, etc.;
• If there are no such individuals, the beneficiary is considered to be a natural person who controls the legal entity in other ways, for example, by being its director, chairman of the board or other collegiate management body, a member or a natural person holding senior managerial positions and who holds the sufficient authority to make decisions on behalf of the legal entity. 

All data you provide to us is strictly protected according to confidentiality rules. We disclose customer data to third parties only with the written consent of the customer or when the information is required to be disclosed by the competent authorities (e.g. law enforcement, tax administration, court, etc.)that have the right to obtain information from the bank and such rights are provided for in-laws. 

Yes, all data provided to Luminor by its customers are confidential and stored carefully as established in the legislation of the Republic of Lithuania – the Law on Banks and the Law on Personal Data Protection. The Lithuanian Law on Banks regulates in which cases, to whom and on what grounds and to what extent information covered by the bank secrecy may be disclosed to third parties, such as institutions performing pre‑trial investigation, criminal intelligence, tax administration, the Deposit Insurance Fund and the Fund of Insurance of Liabilities to Investors, supervision of personal data processing, supervision of financial market, disputes' settlement between the consumers and financial market participants out of court in accordance with the Law of the Republic of Lithuania on the Bank of Lithuania, functions of prevention of money laundering and/or terrorist financing, notaries and bailiffs, if they need to perform the functions for notaries and bailiffs established by laws. The bank secrecy – the essence of the bank‑customer relationship – is also regulated by the General Rules of Luminor Bank.

By requesting additional information or documents we do not violate the regulation, but implement the principle "Know Your Customer" and other legal requirements. We ask to provide information about the true beneficiaries because we are obliged by the legal acts  to understand the customer‘s management structure and identify the natural persons who have control over the company.

Legal regulations oblige us to obtain the necessary for getting to know our customers directly from them. The information held by these institutions can only be used as an additional data source to verify the information provided by you.