Sanctions

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

• the restrictions stem from sanctions implemented by the European Union or a partner country of the North Atlantic Treaty Organization (NATO), and
• the compliance substantially affects the interests of the participants of the financial and capital market or the interests of the financial and capital market.

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:

1. engaging, either directly or indirectly, in transactions or provision of services, or in  any activities for the ultimate benefit of countries subject to sanctions;
2. engaging in any activities (into which legal entities or individuals or vessels that appear on sanctions lists are involved), either directly or indirectly.

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:

• The United Nations (UN) Security Council consolidated sanctions list;
• The EU’s consolidated sanctions list of persons, groups and entities;
• The US Department of the Treasury, Office of Foreign Assets Control sanctions lists (OFAC);
• The UK HM Treasury (HMT), Office of Financial Sanctions Implementations, consolidated list of targets;
• Internal list of entities and persons. 

References related to sanction questions:  

• Official website of the Ministry of Foreign Affairs of the Republic of Latvia
• Official website of Latvia’s Financial Intelligence Unit (FIU Latvia)
• Law On International Sanctions and National Sanctions of the Republic of Latvia
• Cabinet Regulation No. 327, Procedures for the Proposition and Enforcement of International and National Sanctions
• The United Nations (UN) Security Council consolidated sanctions list
• The EUs consolidated list of sanctions
• EU Best Practices for the effective implementation of restrictive measures
• Guidelines on implementation and evaluation of restrictive measures (sanctions) in the framework of the EU Common Foreign and Security Policy
• The US Department of the Treasury, Office of Foreign Assets Control (OFAC) sanctions lists
• The US Department of the Treasury, Office of Foreign Assets Control (OFAC) sanctions list search tool
• The US Department of the Treasury, Financial Crimes Enforcement Network (FinCen) advisories
• The UK HM Treasury (HMT), Office of Financial Sanctions Implementations, consolidated list of targets
• COUNCIL REGULATION (EC) No 428/2009 of 5 May 2009 setting up a Community regime for the control of exports, transfer, brokering and transit of dual-use items (List of the EU dual-use items)
• Common Military List of the European Union