In order to comply with the applicable sanction-specific rules and regulations, Baltic International Bank SE (here referred to as Bank) has articulated the Sanctions Risk Management Policy (here referred to as the Sanctions Policy).
The purpose of the Sanctions Policy is to ensure (in accordance with the International and the Republic of Latvia’s National Sanctions Act, here referred as the Sanctions Act) Bank's compliance with the sanctions directly applicable in the Republic of Latvia (such as national sanctions, sanctions imposed by United Nations Security Council, and sanctions implemented by the Council of the European Union).
Bank complies with the FCMC’s (Financial and Capital Market Commission) requirements binding upon the participants of the financial and capital market with respect to the application of financial restrictions if
Bank is fully compliant with OFAC (U.S. Department of the Treasury Office of Foreign Assets Control) sanctions. This means that Bank fully complies with OFAC sanctions requirements for payments in any currency, including U.S. Dollar payments.
A strong sanctions compliance culture and responsibility for compliance with international sanctions make the foundation of Bank’s values and of Bank’s sustainable and ethical business practices. For Bank, sanctions compliance is not only a moral imperative and law-mandated obligation prescribed by the Sanctions Act. Bank’s values are built upon integrity, honesty, forward-looking development and family values, which cannot be cultivated and integrated into Bank’s ideological understandings without Bank’s responsible approach to combating human rights violations and outrage against humanity and freedom.
Bank understands and is aware of that it can be exposed to sanctions risk while providing financial services. To drive down the level of sanctions risk, Bank takes preventive measures to identify and avoid the risk of sanctions violations.
Driven by the intention of protecting itself, it employees, customers, its own reputation and the reputation of the financial industry overall, Bank reserves the right to make decisions barring Bank from conducting certain transactions or providing certain services, even though the transactions or the services are not prohibited by sanctions, but Bank reasonably believes that the transactions or the services are exposed to the risk of potential sanctions violations.
Thus, Bank's Sanctions Policy prohibits all activities that contradict the applicable sanctions laws or Bank's Sanctions Policy, such as:
Bank can approve certain transactions related to sanctions, for instance, those which are allowed under a licence from a competent authority. The transactions will be considered on a case-by-case basis, and the respective customer must submit to Bank all supporting documents and information for the transactions before the execution thereof.
The requirements of the Sanctions Policy apply to all of the functional units and Bank’s employees involved in providing, handling and monitoring of Bank’s financial services. The requirements of the Sanctions Policy apply to all products and services offered by Bank.
Bank complies with the following sanctions lists:
References related to sanction questions: