Know your customer
A bank is based on trust, good service, the right solutions and the conviction that a bank knows its customers. As we want to know more about you and your situation, we ask you different questions. If we know you, then we can offer you good advice and provide banking services that correspond to your needs.
However, there are questions we ask for other reasons. Nordea is one of Europe`s largest banks and we uphold principles of corporate social responsibility. Banks have to follow many laws, including ones aimed at preventing money laundering, terrorism and economic crimes.
We ask you questions when you become our customer and regularly turn to all customers with the request to update data.We cannot always provide a service
In rare cases, when we do not receive enough information from a customer, we are not permitted to provide a requested service. You can read more about banks` obligations and related issues on the Banking Association`s homepage.
We ask you to review your contacts, citizenship, country of birth and the country you pay taxes in. Aside from personal information, we are interested in your place of employment, financial status, origin of funds received at oru bank etc.
We also need to find out whether you or a family member or a person close to you is a PEP – politically exposed person, whose role in society brings heightened attention.
All your data is confidential.
Options for renewing customer data:
Customer data renewal in Netbank
The customer data questionnaire in Netbank`s upper right-hand menu: Settings -> Customer data.
Filling in the questionnaire in Netbank is secure, because your person will be identified in Netbank before you answer the questions. You can check the security of Netbank and SSL-protocol by clicking on the padlock icon on the address bar at the top or bottom of the screen.
Customer data renewal in Self-service portal (possible only for corporate customers)
Corporate customers can update their customer data in Self-service portal.
Renewing customer data in a bank office
You can fill in the customer data questionnaire in our bank offices with the assistance of a bank employee.
Find the nearest bank office address from kaart.nordea.ee.
- Banks general terms and conditions
- Money Laundering and Terrorist Financing Prevention Act
- Financial Supervision Authority guideline ”Money laundering and terrorist financing prevention measures in credit and financing institutions”
- Agreement between the Government of the Unites States of America and the Government of the Republic of Estonia to Improve International Tax Compliance and to Implement FATCA Ratification Act
- Tax Information Exchange Act
- Private customer questionnaire
- Corporate customer questionnaire
Exchange of tax information under FATCA
Estonia and the US signed an intergovernmental agreement on improving international tax compliance (IGA) on 11.04.2014, based on US tax act FATCA (Foreign Account Tax Compliance Act – a legal act aimed at increasing US state budget income and improving declaration of taxes). Pursuant to this agreement, Estonian financial institutions must identify customers, who must pay taxes in the USA.
The term US person also includes residents and citizens of the United States of America, including residents with a permanent residence permit (Green Card holders) and citizens of the United States of America with multiple a citizenship, and companies registered in the United States.
Estonian financial institutions are obliged to submit the information regarding US persons of USA (including the data on the account owner, info on tax residency and account balance) to the Estonian Tax and Customs Board, which in turn, forwards this information to the US Internal Revenue Service – IRS. You can read more about IGA and FATCA on the webpage of the Ministry of Finance www.fin.ee/fatca and on the webpage of US Internal Revenue Service www.irs.gov.
Exchange of tax information under CRS
The CRS (Common Reporting Standard) is a global reporting standard aimed at addressing the issue of offshore tax evasion by disclosing financial accounts held by non-residents and automatically providing governments with that information.
Under the CRS, jurisdictions like Estonian Tax and Customs Board obtain financial information from their financial institutions and automatically exchange that information with other jurisdictions on an annual basis. Exchange of information regarding to CRS between EU and OECD Member States starts on 2017, but collecting information from customers started already on 2016. More information related to CRS can be found on OECD webpage http://www.oecd.org/tax/.
How will the exchange of tax information affect Estonia customers?
Starting 1 January, Estonian financial institutions are obliged to ask all new customers to provide the bank with all tax residence countries (including USA) where customers pay taxes and their taxpayer identification number (TIN).
Within the next two years, bank will contact existing customers who may be reportable under the CRS.
Please be aware that if a customer does not provide the required information, the financial institution will be obliged to submit data of the person to the Tax and Customs Board. Please be advised that bank cannot give you any FATCA and CRS-related tax advice. If you have tax-related questions, please contact a tax specialist or visit the webpages www.irs.gov (FATCA) and http://www.oecd.org/tax/ (CRS).
Forms to provide FATCA and CRS tax-related information
If you are a taxable person (individual, as well as legal person) in any country than Estonia, we ask you to fill in the combined FATCA and CRS self-certification form where shall be added all tax residence countries and respective tax identification numbers – TINs.
|Why am I required to provide/update my information?||The bank must follow the principle “Know your customer”. For a bank it means to follow statutory procedures and requirements that are created for prevention of anti-money laundering and terrorism financing. Following this principle, banks have e.g. the obligation to obtain information about customers, affiliated persons and the origin of customers’ funds. Once the information is obtained it shall be periodically reviewed and updated.By the updating required information you will enable bank to provide the best banking services in accordance with Your needs. At the same time, by answering the questions of the bank You will help to prevent crimes, particularly money laundering and terrorism financing.|
|What laws and regulations are behind the "Know Your Customer" principle?||The "Know your customer" principle is governed by Money Laundering and Terrorism Financing Prevention Act.|
|To whom the data provided by the customer are shared?||The Bank protects all the information provided by the customer. Any information about a customer is strictly confidential and Bank`s duty is to guarantee the confidentiality of all information provided by customer. The Bank shall disclose any information only in accordance with General Terms and Conditions of the bank and under relevant laws.|
|Why the customer is asked to provide information about the relation with politically exposed persons (*)?||Politically exposed persons are often associated with some potential risks to be involved in the bribery and corruption schemes. Pursuant to the statutory requirements for prevention of anti-money laundering and terrorism financing the Bank must apply strengthened scrutiny in case the relationship with politically exposed person or affiliated person is being started or continued.|
|What channels customer can use to provide the required information?||
For the convenience of the customer we have established several channels where the information can be submitted:
Post: Customers will receive pre-paid letters with the KYC questionnaire enclosed, which can be completed and returned to the bank;
Netbank: Customers can complete the client questionnaire available on the ‘Settings’ page under ‘Customer data’;
Our branch: Customers can visit banks branch in the country where their account has been opened. Please note that this will be the only option to complete the questionnaire for those customers, who have received closing letters.
|What happens if customer does not provide the information to the bank?||If a customer does not provide the requested information and documents required also in cases when false information is provided, the bank may limit provision of banking services or may terminate the business relationship with the customer and request for early execution of obligations.|
|What is a deadline for providing information?||The customer has to provide required information within 30 days since the day he has received a message to update his/ her data. If fully completed KYC questionnaire has not been received by the set deadline we may limit the provision of banking services or terminate the business relationship with the customer.|
|How often Bank has to renew customer information?||Considering the fact that customers’ data and financials change constantly bank needs to renew and keep customer’s information up to date. Banks are obliged to obtain and update necessary KYC information on regular basis, by asking Customers to complete special questionnaires or other forms.Based on The law on Prevention of Money Laundering and Terrorism Financing and Regulatory rules by the FCMC regarding enhanced customer due diligence issued for credit and licensed payment and digital money institutions.|
(*) Politically exposed persons - natural person who are or have been entrusted with prominent public functions, including functions in the Republic of Latvia,
European Community, international or foreign states’ institutions:
- head of State, head of government, minister and deputy or assistant minister, state secretary, the chancellor of the parliament,
- government or ministry;
- member of parliament;
- member of supreme court, of constitutional court or of other high-level judicial body whose decisions are not subject to further appeal;
- members of court of auditors or of the board of central bank;
- ambassadors, chargés d'affaires and high-ranking officers in the armed forces;
- members of the administrative, management or supervisory bodies of State-owned enterprise;
- head, deputy head, member of the administrative, management or supervisory body of international intergovernmental organization;
- leader, deputy leader, member of the administrative, management body of the political party
Close family members – means the spouse, the person with whom partnership has been registered (hereinafter – cohabitant), parents, brothers, sisters,
grandparents, grandchildren, children and children’s spouses, children’s cohabitants.
Close associate - means a person who participates in the same legal entity or maintains other business relations.
|Why does Luminor ask its customers questions via Netbank?||Pursuant to the law, banks are required to know their customers and how they use bank services.
We collect and update data flexibly through the channels our customers use. A secure connection to the Netbank is a safe and easy way to submit data.
|Who receives the questionnaire?||The questionnaire is sent to all online bank users whose personal data needs to be enhanced or updated after a certain amount of time has passed.
Personal data is also updated when customers visit our bank offices, which is why we do not send the web questionnaire to all customers.
|When do customers receive the questionnaire?||Customers receive the notification regarding the need to update data a few months prior to the deadline for updating data to afford ample time to fill in the questionnaire at a suitable time.|
|How can I tell that its Luminor`s questionnaire?||You can check the webpage and SSL protocol security in the Netbank by clicking on the padlock icon on the address bar at the top or bottom of the screen depending on your browser version. When you click on the padlock icon, you will see the VeriSign certificate, which confirms that this webpage belongs to Luminor Bank AS.
The bank never asks you for your access codes, card data or PIN code by e-mail or telephone.
If you suspect fraud or being directed to a fraudulent site, please contact customer support at +372 710 1134 (24/7).
|Can I choose when to fill in the questionnaire?||
Yes you can. You can skip the questionnaire by clicking “Fill in later“, and in this case, the questionnaire will reopen the next time you log in to the Netbank.There is a specific number of times you can do this, and you will be notified if the next time you log into the Netbank, you must fill in the questionnaire, otherwise it will not be possible to use the Netbank.
|Do I need to fill in the questionnaire again when my data changes?||Yes. If your data has changed, we request that you update it in the Netbank at a time suitable to you.|
|Where do I get assistance, if need be? Where can I give feedback on the online questionnaire?||If you have any problems filling in the questionnaire or you want to give feedback about it, then please contact customer support at +372 710 1134 (24/7).|
|Can customer support or office worker fill in the questionnaire for me?||The questionnaire only opens in Netbank in connection with services provided to you and therefore, you must submit the data personally.|
|Doesn`t Luminor already have this data about me?||We cannot and do not wish to collect data about customers without their approval – therefore, even in case of a long-term customer relationship, the questionnaires include questions the bank should seemingly already have answers to.|
|Where can I review the customer data Luminor has saved about me?||You can submit an inquiry regarding your personal data in our bank offices.|
|Is the information disclosed to third parties?||The Bank protects all the information provided by the customer. Any information about a customer is strictly confidential and Bank`s duty is to guarantee the confidentiality of all information provided by customer. The Bank shall disclose any information only in accordance with General Terms and Conditions of the bank and under relevant laws.|
|What happens if I do not provide the information to the bank?||If a customer does not provide the requested information and documents required or also in cases when false information is provided, the bank may limit provision of banking services or may terminate the business relationship with the customer and request for early execution of obligations.|
|Is it possible to keep an account active without updating KYC data?||If a client does not provide the information and documents required, the bank shall limit provision of banking services or may terminate the business relationship with the customer and request for early execution of obligations. So everyone is invited to timely submit all the necessary information when it is requested.|
|What is FATCA?||
FATCA (Foreign Account Tax Compliance Act) is tax legislation valid in the United States of America.
|What does FATCA require?||
Pursuant to FATCA, financial institutions are obliged to ascertain which of their private or corporate customers are US persons and submit reports on accounts and assets directly or indirectly linked to these customers on an annual basis. Usually, the financial institutions report to the corresponding country`s Tax Board.
|Does corresponding to FATCA replace fulfilling other US tax requirements?||
It does not. FATCA and related local legislation only regulates submission of analysis and reports on customer`s business operations required from financial institutions. This does not affect your obligation to fulfil tax legislation.If you have questions regarding fulfilling tax requirements, then Luminor recommends consulting with a tax expert.
|What must Luminor do to correspond to FATCA requirements?||
|Is Luminor the only bank that must follow these requirements?||It is not. All financial institutions must fulfil FATCA requirements. However, their approach may differ from Luminor's.|
|Another bank contacted me. Why do they ask for different documents than Luminor?||
Financial institutions may choose the way they collect data from customers and check FATCA status. That is why the ways data is collected may differ.Luminor cannot advise you on FATCA classification and US tax status issues. If you require additional assistance, then you should consult a tax expert.
|Which data does Luminor submit to the local tax board?||Data submitted for 2014 include the name, address and US taxpayer number and account numbers and balances.|
|How does it affect individuals?||
Does it only affect me if I am a US citizen?
Please take into account that financial institutions are required to revise their customer data in order to identity US persons. Due to this, customers who are not actually US persons may be contacted.
|I am a US person and major shareholder in the company. How does it affect me?||
As you are a major shareholder, then you are probably one of the company`s beneficiaries or a controlling partner.Luminor may be required to submit data about you, but it depends on your company`s business operations. If your company is not active in business (i.e. it is a so-called passive company), then Luminor must submit data about you if you are this company`s beneficiary or controlling partner. A company is regarded as passive if more than 50% of the company`s income is interests or dividends.
|How does it affect companies and legal persons?||
Does it only affect US companies?
|Which documents do I need to submit?||Luminor contacts customers the law pertains to and provides a full overview of the data required to follow FACTA requirements and which forms must be filled in. These forms may include self-certification forms, US tax forms or certificates of withheld taxes (so-called W-forms).|
|Does Luminor provide all necessary forms?||When Luminor contacts a customer, then it sends the necessary forms or a link to the webpage where these can be downloaded.|
|What will Luminor do if I do not submit the data required by FATCA?||
Pursuant to FATCA, financial institutions are obliged to consider customers who have not submitted the required data as liable to pay tax in the US. This means that Luminor will submit the same data about these customers to the local Tax Board as for customers who have submitted the bank documents that confirm their US person status.In case of exceptions, financial institutions may be required to withhold tax on payments that are received from certain US sources, which have come into the accounts of customers who have not submitted the required documents.