For financial institutions

Luminor is a Bank that provides comprehensive range of banking services and strictly follows the broad range of anti-money laundering and counter terrorist financing (AML/CTF) regulations in each country where Luminor 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 local legal acts, other local and European Union regulations 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 Luminor operates, Bank rejects any request to execute transaction or provide financial services in breach of applicable regulations.

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

General compliance statement relating to AML/CFT
USA Patriot Act Certification
Wolfsberg CBDD questionnaire

For customers

What Is Money Laundering?

Money laundering includes acts which aim to legalize money or other property acquired by 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.

Estonian Money Laundering and Terrorist Financing Prevention Act (hereinafter AML Act) and Guidelines by Estonian Financial Supervision Authority establish the preventive measures to be taken by the banks and other subjects in order to prevent money laundering and terrorist financing.

Compliance with the requirements for prevention of money laundering and terrorist financing in Bank is regulated by relevant internal procedures. The purpose of these procedures is to assist the employees of the Bank to duly implement all necessary requirements regarding prevention of money laundering in all their activities. All structural units and subsidiaries of the Bank are obliged to follow the procedural rules.

 “Know Your Customer“ principle

Luminor Bank follows the "Know your customer" principle. This implies that Bank employees have to understand customer activities. In order to enable the Bank to know the customer, all private persons and legal entities need to fill in relevant questionnaires about their activities and Banking necessities. It is necessary for the Bank to receive information about customer‘s financial activities, sources of funds, geographical dimension of their activities etc. In addition to complying with laws and regulations, gathering this information  helps to understand customer‘s needs, it is easier to offer suitable products and services for customer. Also, implementation of  “Know your customer“ principle helps to prevent possible money laundering and protect our customers from fraud.

Additionally, the Bank has to identify the actual beneficiary of customer’s accounts - 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 Act it is also necessary to identify if customer, customer‘s close family members or close associates are considered as Politically Exposed Persons who are or were entrusted with prominent public functions in Estonia or abroad.

If the aim of a transaction is not clear, the Bank employees need to ask for more information and possibly evidencing documents about the purpose of this 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 sufficiently verified, ability to use the funds could be restricted.
The Bank protects all the information provided by customers concerning their activities. Customers 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 continuously observe these business relations.

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 and documents 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 or refuse to establish the business relationship with relevant customer.

  Estonian Banking Association: Combating money laundering and terrorism financing in Estonia