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Know Your Customer Form

What does Know Your Client principle mean?

The laws of the Republic of Lithuania stipulate the obligation for all banks to follow the Know Your Client principle in their activities and to regularly update information about the activities, sources of income and financial operations of their clients.

This information is necessary for banks in the prevention of money laundering and terrorist financing, as provided for in the Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania as well as other national and international legislation.

To get to know its Clients both before and during the course of the business relationship, the Bank asks the Clients to fill in a Know Your Client Form, in which the Clients are asked to provide basic information about themselves, their business activities, sources of income, financial transactions and the purpose and nature of the relationship with the Bank. Pursuant to the law, the Clients are also asked to indicate whether they or their close family members or close associates are politically exposed persons.

We request this information from natural persons and legal entities in the Republic of Lithuania, as well as from our foreign Clients for whom it is important to clarify their social or economic ties with Lithuania.

There are three ways to fill in the Know Your Client Form

  1. through the Internet Bank. You can find the form under menu item “Other services” -> “Know Your Client Form”.
  2. through the Dokobit portal, by signing the form electronically (for instructions, click here).
  3. if the above options are not available to you, make an appointment in the manner most convenient to you (by telephone at 1813 or online) and visit the nearest customer service unit of the Bank.

Why is it necessary to fill in the Know Your Client Form?

Banks collect this information because they are obliged to do so by legal requirements in the area of prevention of money laundering and terrorist financing. Pursuant to the applicable legislation, banks implement the Know Your Client principle, which obliges them to collect up-to-date data on their clients, and helps to protect clients against fraud.

Banks are required to know who their clients are and what their normal activities are, and to ensure that transactions of their clients are in line with the scope and scale of their economic activities.

More information here.

How often do you need to fill in the form?

Periodically, once every 1–3 years, depending on the type of your activities and whether you are a private/business client. In any event, the bank will personally inform you in advance of the upcoming time to update the Know Your Client Form.  

Important! Clients are required to inform the bank about any changes to the information provided, including their contact details.

What happens if I fail to fill in the Know Your Client Form in time?

We may not be able to provide some or all of our services to you. In such event, restrictions may apply to the use of a personal bank account, payment card(s), Internet Bank, smart application, other services. You will be able to continue using the services after submitting a completed Know Your Client Form.

Why are certain questions included in the form?

The Know Your Client Form helps us to collect and, in the course of the business relationship, update information about the activities, sources of income, business partners and financial operations of our clients, thus preventing money laundering and terrorist financing.

Why can’t you update this information using other public sources (e.g., the State Tax Inspectorate, the Centre of Registers)?

We have an obligation to receive the information necessary for getting to know our clients directly from the clients. Information received from other authorities can only be used as an additional source to verify the information that you provided.

Why does the Bank ask for the Taxpayer Identification Number and information of the country of residence for tax purposes?

The Bank is obliged by law to collect information on the tax residency of its Clients and their ultimate beneficiaries/controlling persons, which is necessary to ensure the implementation of the international cooperation obligations on the automatic exchange of information on financial accounts. The Bank, like other credit institutions, provides the collected information, including the Client’s tax residency details and Taxpayer Identification Number (TIN), to the State Tax Inspectorate in accordance with the established procedure.

What does “resident for tax purposes” mean in the form?

A resident for tax purposes is a natural person who is treated as a taxpayer under the national law of the country concerned, e.g., if he/she has his/her domicile of residence in a particular country during the tax period, or if he/she has stayed in the country for a period of more than 183 days in a 12-month period, or if he/she has his/her personal, social or economic interest in the country during the tax period, or if any other criteria for taxation of income under the laws of that country are met.

If you are a resident for tax purposes in more than one country, please indicate all countries and the Taxpayer Identification Number (TIN) in each country, as issued by the national tax authority of that country.

What is the Taxpayer Identification Number (TIN)?

The Taxpayer Identification Number (TIN) for individuals who pay taxes in Lithuania is a national identification number, while for legal entities it is a company registration number.

In the USA, TIN for natural persons consists of 9 characters, where 1–3 and 4–5 characters are separated by a hyphen (e.g., xxx-xx-xxxx).

The foreign national identification numbers (codes) must follow the general structure of Taxpayer Identification Numbers (TINs). The structure of Taxpayer Identification Numbers for different countries is available here.

What is FATCA and/or CRS?

FATCA (Foreign Account Tax Compliance Act) is an international standard for the automatic exchange of financial account information, which governs the periodic exchange of account information of US citizens or US taxpayers between countries that have signed a treaty with the USA: https://www.irs.gov/

CRS (Common Reporting Standard) is an international standard for the automatic exchange of financial account information that aims to combat international tax evasion. Financial institutions are required to identify financial accounts belonging to Clients who are resident for tax purposes in a country or jurisdiction other than the country or jurisdiction of the financial institution and to report such accounts to the country’s tax authority: https://www.oecd.org/tax/automatic-exchange/common-reporting-standard/

Why does the Bank ask about involvement in politics?

The Law on the Prevention of Money Laundering and Terrorist Financing (as well as international legislation) stipulates the obligation of the Bank to find out whether its clients and their immediate family members or associates are involved in political activities and qualify for the status of a Politically Exposed Person (PEP).

Who are considered to be Politically Exposed Persons, their immediate family members or close associates?

A Politically Exposed Person is a natural person who is currently, or has been within the last 18 months, holding a prominent public function in any state and/or international or foreign institution, and his/her immediate family members and/or close associates.

Immediate family members include spouse, registered partner (hereinafter, common-law partner), parents, brothers, sisters, children and children’s spouses, common-law partners.

Close associates include:

  1. natural person who is a participant of the same legal entity or organisation without legal personality or maintains other business relationship with the natural person who is or was holding prominent public function.
  2. natural person who is a sole beneficiary of a legal entity or organisation without legal personality incorporated or acting de facto for material or other personal benefit of the natural person who is or was holding prominent public function.
What is a prominent public function?

Prominent public functions: a position in the Republic of Lithuania, the European Union, international or foreign institutions:

  1. head of state, head of government, minister, vice-minister or deputy minister, state secretary, chancellor of the Parliament, the Government or a Ministry.
  2. member of parliament.
  3. member of the Supreme Court, Constitutional Court or other supreme judicial authority whose decisions can not be appealed against.
  4. mayor of municipal government, director of municipal administration.
  5. member of the governing body of the supreme state audit and control authority or chairperson, deputy chairperson or member of the board of the central bank.
  6. ambassador, chargé d’affaires, special envoy and minister plenipotentiary or high-ranking military officer.
  7. member of the governing or supervisory body of state enterprise, public limited liability company, private limited liability company whose shares or part thereof, granting more than 1/2 of all votes in the general meeting of shareholders, are owned by the state.
  8. member of the governing or supervisory body of municipal enterprise, public limited liability company, private limited liability company whose shares or part thereof, granting more than 1/2 of all votes in the general meeting of shareholders, are owned by the municipal government, and which are considered large enterprises according to the Law on Financial Reporting by Undertakings of the Republic of Lithuania.
  9. head of an international intergovernmental organisation, its deputy head, member of its governing or supervisory body.
  10. leader of a political party, its deputy leader, member of its governing body.
Who is considered to be the beneficiary, the owner of a legal entity?

Direct owner is a natural person who directly controls a legal entity by holding more than 25% of the shares, stocks, contributions, units and/or votes in the legal entity.

Indirect owner is a natural person who controls, through other legal entities, an enterprise or several enterprises in which more than 25 % of the shares, stocks, contributions, units and/or votes of the natural person are held.

A natural person who otherwise controls a legal entity, for example, by having the right to appoint or remove the legal entity’s manager and to take strategic decisions.

In the absence of such persons, the beneficiary is a natural person who otherwise controls the legal entity, e.g., is its manager, chairman/chairwoman, member of the board or other collegial management body, or a natural person holding a senior management position, and who holds a sufficiently senior position to take decisions on behalf of the legal entity.

All of the following are deemed to be the beneficiaries of a client/trust fund:

  • the settlor(s)
  • the trustee(s)
  • the custodian(s), if any
  • the natural persons who benefit from the client or, if these persons have not yet been identified, the persons in whose interests the client is established or acts
  • any other natural person who effectively controls the client through direct or indirect ownership or other means.
Why do I need to provide information on the beneficiaries and participants of a legal entity?

Pursuant to the Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania, all legal entities established in Lithuania (except for those whose sole participant is the state or a municipality), as well as collective investment undertakings, are obliged to obtain, update and store accurate information on their beneficiaries and to provide this information in the Information System of Legal Entities Participants, sub-system JANGIS.

Why is it important to provide information about beneficiaries on the Centre of Registers sub-system – JANGIS?

It should be noted that if the information held by financial institutions and other obliged entities* on the beneficiaries of the Client (legal entity) does not correspond to the information provided in JANGIS, or if the above-mentioned information has not been provided in JANGIS at all, business relationship or monetary operations and transactions with such Client may not be commenced and/or executed.

* Other entities, such as auditors, bailiffs, notaries, etc., are also obliged to use data on beneficiaries when providing services.   

How is the information stored?

The bank ensures that the information provided by the clients is stored in the same way as any other information that constitutes a bank secret. More information on how and what personal data we process can be found in the Personal Data Protection Rules of the Bank.