We are obliged by national and international legal acts governing the prevention of money laundering and terrorist financing to follow the "Know Your Customer" (KYC) principle. This means that we are required to collect certain information about our customers (e.g., information about payment habits, sources of income), to be able to respond to unusual activity spotted in their transactions. This information must be monitored and updated on a regular basis; therefore, we ask our customers to provide and/or update the KYC questionnaire.

We monitor financial transactions to identify any outlier activity. In case of discrepancies, we ask our customers to clarify information and provide additional documents. Therefore, it is very important to update the KYC questionnaire in a timely manner and provide accurate and up‑to‑date information. We ask customers to inform us about any significant changes, such as a change of the company's director or beneficiary, or, in the case of the individuals, a change of job, changes in turnover, or residential (business operation) location. This way, we can more easily ensure the security of accounts and prevent possible illegal or suspicious activities.

We check such information to understand the basis for making the payment and the nature of the business relationship between the payer and the payee. That is why we kindly ask our customers to provide a  clear and detailed description of the payment purpose avoiding any ambiguity.

A request for information does not mean that you are suspected of something. We do not collect customer data on our own initiative, but because we are required by law to do so. This is a routine procedure we apply to all our customers.

We must ensure that the transactions carried out by our customers match their profiles. This way, we can protect the interests of our customers and assess the possible risk of fraud.

The majority of our customers do not participate in illegal activities and should not worry about such questions. However, by answering our questions they can help us identify actual violations more effectively.

According to law, we are obliged to know the origin of your funds. For this reason, we ask you to provide the documents supporting the legitimate origin of the funds, such as certificates from your employer or income tax declarations submitted to the State Tax Inspectorate (STI), purchase and sale agreements for movable or immovable property, gift agreements, purchase and sale agreements for goods/transport documents/invoices. We reserve the right to evaluate each case individually.

All data provided by you are handled in a strictly confidential manner.

We only disclose your data to third parties if we have your written consent, or upon the request of the competent authorities (law enforcement, tax administration, court, etc.) that have a statutory right to receive such information from the bank.

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 Law on Banks of the Republic of Lithuania regulates in which cases, on what grounds, and to what extent information covered by the bank secrecy can be disclosed to third parties, for example, to institutions performing pre‑trial investigation, criminal intelligence, tax administration, 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, money laundering and/or terrorist financing prevention functions, notaries and bailiffs, if they are necessary to perform notarial and bailiff functions provided for by law. The bank secrecy – the essence of the bank‑customer relationship – is also regulated by the Luminor General Rules.;

By requesting additional information or documents we do not violate the regulation but implement the principle of "Know Your Customer" and other legal requirements. We ask to provide the information about beneficial owners because we are obliged by the legal acts to understand the customer's management structure and identify the natural persons controlling the company.

The request for additional information from third parties is based on the requirement of the Law on the Prevention of Money Laundering and Financing of Terrorism for financial institutions to take appropriate measures to determine the source of funds related to business relationships or transactions. The origin of funds helps us determine whether the transaction is related to illegal activity and is in line with the nature of the customer’s business. 

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

Under 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 fails to submit the information confirming the origin of c (assets), the nature of operations, business relationships with counterparties, information about the company's management structure and true beneficiaries or other relevant information; provides incomplete or inaccurate data, or refuses to provide additional information requested by the bank within the specified timeframe. The same article states that in such cases when the customer avoids or refuses to provide additional information requested by the bank within the specified timeframe, the bank we may refuse to carry out financial transactions or terminate transactions or business relationships.