Customer data

Relationship between a bank and its customers is based on mutual trust. We care about our customers’ trust; we, therefore, periodically publicly announce our financial results and other performance reports. Accordingly, we ask our customers to provide certain information about them as well.

Provision of information is important for several reasons. First, banks must comply with very strict legal requirements which oblige them to implement the ”Know Your Customer (KYC)” principle. Implementation of this principle is related to application of international measures aimed at prevention of money laundering and terrorism financing. Banks must ensure that their infrastructure is not abused by malicious entities or by persons who pose threat to others.

Another important reason is that banks care about their customers’ security and the security of their accounts. With up-to-date details available, we can ensure safety of accounts more easily, prevent illegal actions by fraudsters, stop suspicious transactions and thereby protect our customers from financial losses.

All of the data you provide us is protected by strict security and confidentiality rules.

We disclose customer data to third persons only if we have received the customer’s written consent or if the disclosure of data is required of us pursuant to law (e.g. a notary, the police, the State Revenue Service and Customs Board).

Information is not collected with the purpose to immediately forward it to other institutions. Information you provide is stored responsibly. In certain cases, when this is necessary, authorised institutions (law enforcement, security provision, etc.) are entitled to address banks and request the provision of information about a customer. In such case, the bank, in accordance with laws, will be obliged to provide such information.

• Banks have a duty to guarantee secrecy of customer’s identity, accounts, deposits and transactions
• Information regarding a customer and their transactions acquired by the bank through provision of financial services under the relevant contract is non-disclosable information
• The bank may disclose such information only to customers themselves or to their representatives except in cases laid down in the Law on Credit Institutions – to government authorities and other persons, as set forth by this law

Due to requirements of legal acts, banks are obliged to identify people with a public authority background whose social role attracts greater attention to them.

A politically exposed person is a person who exercises or has exercised prominent public functions. The family members of this person are considered family members of a politically exposed person, but close co-operation partners are considered to be persons closely associated to a politically exposed person. Persons who have not exercised prominent public functions for at least a year are not deemed to be politically exposed persons.

Family members of a politically exposed person:

• a spouse or a person equivalent to spouse;
• a child or a child of a spouse or a person equivalent to a spouse, his or her spouse;
• a parent;
• a brother, or a sister.

Person closely associated to a politically exposed person:

• a person who has business or other close relations with a politically exposed person;
• a person who is a shareholder in the same legal entity as a politically exposed person;
• a person is the only owner of such legal arrangement established for the benefit of a politically exposed person.

Please review the list of the relevant positions provided below

The respective legislation can be found below:

• Law on Prevention of Money Laundering and Terrorist and Proliferation Financing
• Legal acts of Latvia
• Law on Credit Institutions
• Law on Taxes and Duties
• Procedures by which a Financial Institution Implements the Due Diligence Procedures for Financial Accounts and Provides Financial Accounts Information to the State Revenue Service
• documentList of countries involved in the automatic exchange of information

According to the Law on International Sanctions and National Sanctions of the Republic of Latvia, we implement national and the following international sanctions:

• United Nations (UN) – all UN member states are obligated to transpose and implement resolutions adopted by the UN Security Council.

  UN Security Council sanctions regimes: https://www.un.org/securitycouncil/sanctions/information

• European Union (EU) – restrictive measures are adopted by EU Council Regulations, which are binding on all citizens and companies of EU Member States.

  EU sanctions regimes (with search function): https://www.sanctionsmap.eu/#/main

• Financial sanctions imposed by the United States of America (USA) and the United Kingdom.

  • In order to provide our customers with payments and other products/services in USD, we maintain relationships with banks under US jurisdiction and comply with US financial sanctions. They are enforced by the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury.

    ASV OFAC sanctions regimes: https://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx

    ASV OFAC search tool: https://sanctionssearch.ofac.treas.gov/

  • Under financial sanctions imposed by the United Kingdom (enforcement agency – OFSI), we can provide payments and services in GBP to our customers by maintaining relationships with UK banks.

    United Kingdom’s sanctions regimes: https://www.gov.uk/government/collections/financial-sanctions-regime-specific-consolidated-lists-and-releases

We take into account both the requirements of our partner banks (correspondent banks) and our internal principles for risk assessment. Consequently, we do not engage in transactions that could directly or indirectly violate financial sanction prohibitions, correspondent banking regulations or our internal sanctions policy.

International sanctions imposed by the European Union (EU), including those imposed by the United Nations, are in force in the territory of EU Member States and apply to all persons who are nationals of an EU Member State, whether inside or outside the territory of EU Member States. Thus, both financial institutions and their customers are legally responsible for complying with EU sanctions and have an obligation to notify the competent authorities not only of transactions involving individuals or entities subject to sanctions, but also of any suspicions that such transactions have taken place.

When engaging in business transactions, every customer must assess the potential risks of sanctions. Information on sanctions is widely available in publicly accessible sources. Customers, especially those operating internationally, need to be aware of and take action regarding sanctions (not just financial sanctions) that could affect their business. This requires customers to assess whether their business activities could be subject to sanctions and to take appropriate risk mitigation measures.

The information provided above is not complete or comprehensive, so customers are recommended to consult the relevant authorities or seek independent legal advice if they have any questions regarding the implementation of sanctions.

In view of international sanctions, Swedbank Group decisions, correspondent bank requirements and the current geopolitical situation, we are obligated and have the right not to execute any direct transactions (including cash and non-cash payments, card payments) in any currency on customer accounts if they are directly related to the following countries or regions ("Prohibited Countries"):

• North Korea
• Syria
• Iran
• Russian Federation
• Crimea and Sevastopol
• The Ukrainian territories of Donetsk, Luhansk, Kherson and Zaporizhia regions not controlled by the Ukrainian government
• Republic of Belarus
• Cuba
• Venezuela
• Afghanistan

We also consider indirect transactions (including cash and card payments) in the accounts of our customers related to the above-mentioned Prohibited Countries to be unacceptable.

All transactions identified in customer accounts that have a direct and/or indirect connection with the Prohibited Countries and that may be found to be unacceptable will be assessed on a case-by-case basis. The following situations, for example, are considered unacceptable:

• Transactions with individuals who live and/or operate in the Prohibited Countries or are connected with them.
• Transactions with legal entities that have been founded and/or operate in the Prohibited Countries or transactions that are connected with them.
• Transactions with underlying export or import of goods or services, funds, or destination that are connected to a Prohibited Country.
• Deposits of cash derived from the income obtained in a Prohibited Country, for example for the sale or rent of property, sold goods and/or services, dividends or funds related to employment in companies and/or organisations established and/or operating in Prohibited Countries.

Important! The term of executing such payment transactions may be extended or they may be blocked or frozen by us or by other banks that participate in the execution of a payment transaction (correspondent bank, beneficiary’s bank or sender’s bank). Therefore, customers should always evaluate potential risks of international sanctions.

In addition to the above restrictions, access to our products and services may be restricted (including initiation/performance of transactions) for customers performing the transactions described above.

In response to Russia's full-scale military attack on Ukraine, the European Union has imposed sectoral sanctions against Russia and Belarus covering a wide range of goods and sectors, as well as unprecedented types of sectoral sanctions. Sectoral sanctions prohibit the direct or indirect purchase, import or transfer of a wide range of goods subject to sanctions, if their origin is Russia or Belarus or they have been exported from Russia or Belarus. The prohibitions also apply to the provision of technical assistance, intermediation services, financing, financial assistance and other services related to the goods and technologies subject to sanctions, as well as to the provision, manufacture, maintenance and use of such goods and technologies.

In accordance with the sanctions imposed, it is prohibited to export the following goods and technologies to Russia:

• Goods and technologies for use in the aviation and space industry
• Luxury goods
• Maritime navigation equipment and technologies
• Goods and technologies suitable for oil refining
• Goods that could significantly contribute to the development of Russian industry
• Other goods subject to sanctions

The following imports from Russia are prohibited:

• Crude oil and refined petroleum products
• Coal and other solid fossil fuels
• Steel
• Gold and jewellery
• Cement, wood, paper and plastics
• Sea food
• Alcoholic beverages
• Other goods subject to sanctions

The European Union has prohibited the provision of certain business-related services to the Russian government and legal entities operating in Russia. The prohibition applies to the following services:

• Accounting
• IT consultancy
• Legal advice
• Architectural and engineering services
• Advertising
• Market research and public opinion research

It is also stipulated that any legal entity, unit or body that is registered in the EU and in which 25% or more of the shares are owned by a Russian individual or legal entity, may not operate as a road transport company engaged in the carriage of freight within the EU, including transit.

Sectoral sanctions against Belarus include trade restrictions, a ban on the supply of certain services, transport and logistics restrictions, as well as sanction violation prevention measures.

Note! The above lists are not exhaustive. A complete list of prohibited goods and services, as well as other restrictions, is available at the links below.

EU Common Military List

EU Dual use controls

EU Council Regulation related to Russia sectoral sanctions

EU Council Regulation related to Belorussian sectoral sanctions

We classify the field of transportation as a high-risk industry due to possible transportation of sanctioned goods (ex. military goods, dual-use goods, goods related to energy sector) and provision of services which are prohibited by the regulatory requirements of the European Union, the United Kingdom, the United States of America and the United Nations.

Note!If you or your company operates in the field of transportation or is connected to this field, then you are required to provide the following information when making payments:

• Information on the goods transported (including certificates of origin of goods, bills, invoices, transportation documents, such as rail, airway bills, etc.)
• Information on the final destination/final recipient of the goods (recipient's name, registration number, country, address)
• Information about the consignor (name, registration number, country, address)

If we request you to provide documents and the information received does not contain all the necessary details, the payment may be delayed, rejected or returned to the sender according to our internal policies.

Note! If you or your company operates in the field of shipping or is related to this field, in accordance with international maritime regulations, you must include the following information in the “Payment details” field:

• Ship: name of the ship
• IMO: International Maritime Organization number
• Flag: flag country
• Owner: name of owner
• Registration: number and country

Otherwise, the payment may be delayed because the payer's bank will require to obtain the missing information. If the payment does not comply with international standards (including US legislation), it may be frozen at the correspondent bank.

Please note that EU Member States, the US, and other countries have imposed a number of restrictions on the shipping industry, for example, Russian and Belarusian ships are prohibited from docking at EU Member State ports. Consequently, if we identify sanction risks during the assessment, the transaction may be rejected or returned to the sender according to our internal sanctions policy.

Proliferation financing refers to any financial resources used to support the distribution of weapons of mass destruction (WMD) or activities to acquire them. This type of financing can be extremely dangerous, as it can contribute to the spread of technologies and materials that threaten global security. We do not engage in any transactions that may be related to the use of funds for proliferation financing.