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European Lithuanian Bank Closure due to AML KYC

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Offshore Agent
Sep 30, 2012
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Urgent Notice from the Lithuanian Bank Swedbank

I guess decision is already made?
Requesting too much and quickly


Dear Customer,

Acting in observance of legal acts and in implementing the principle ‘Know Your Customer’,
we are asking you to provide in writing the information and/or documents:

1. What is your source of income?
• Please specify the source from which you receive your income by choosing one of the following
options:
(i) wage / pension / social benefit;
(ii) income from dividends;
(iii) income from rent of immovable property;
(iv) income from transactions in financial instruments;
(v) transfers from relatives;
(vi) other sources of income (please specify).
• If you are employed, please specify the name of your employer and the city and country where
you work;
• If you are a pupil or student, please specify the name of your educational institution and the city
and country where you learn (study).
• If you are an entrepreneur / a self-employed individual, please indicate the business type(s)
(e.g., in the case of trade – retail and/or wholesale trade, the goods and/or raw materials traded;
in the case of production – the type of manufactured products; in the case of consulting and/or
services – in what sphere, etc.) and whether you hold a valid business certificate / a valid
individual activity certificate.
• If you engage in other activity, please indicate (specify).

2. From what countries are you planning to receive payments to the accounts held
with Swedbank?
• Please specify the countries from which you are planning to receive payments.
• Please specify the most common reasons for receiving payments from foreign countries.

3. To what countries are you planning to make transfers from the accounts held with
Swedbank?
• Please specify the countries to which you are planning to make transfers payments.
• Please specify the most common reasons for making transfers to foreign countries.

4. Do you have accounts with other financial institutions?
• If yes, please specify the names of such financial institutions and foreign countries where you
have the accounts.

5. Please explain the below specified operations carried out in the account(s) opened
in your name with Swedbank:

1. From THE CURRENCY CLOUD LIMITED
on 01-2021 / 04-2021, total 27.980 EUR.
2. My Own Bank Account at Fidor AG, from Germany
on 09-2020 / 06-2021, total 22.241 EUR.

• Please explain on what basis the operations were/are carried out in the account held in your
name with Swedbank with the above referred person(s), indicating the goods and/or services,
the activities, the countries where those activities were carried out and the transactions in
respect of which those operations were/are carried out.
• Please provide the documents (contracts, invoices, consignment notes of movement of
goods, CMR, etc.) by which you can support such operations.

6. Please explain the below specified operations carried out in the the account(s)
opened in your name with Swedbank:

To NEXO SERVICES OU




on 06-2020 / 09-2020, total 35.992 EUR.

To CELSIUS NETWORK LIMITED 1 BARTHOLOMEW LANE, LONDON, UK, EC2N 2AX
on 12-2020 / 02-2021, total 2791.45 EUR.

• Please explain the business relationships or other links existing between you and the payee /
payer, also specify the basis on which the above specified operations were / are carried out,
indicating the goods and/or services, the activities, the countries where those activities were
carried out and the transactions in respect of which those operations were/are carried out.
• Please provide the documents (contracts, invoices, consignment notes of movement of
goods, CMR, etc.) by which you can support such operations.

7. Please explain the purposes of use of cash withdrawn from the account(s) opened
in your name with Swedbank on 12-2020 / 05-2021, total 13.100 EUR.
• Please explain the purposes for which the withdrawn amount of cash was used.
• Please provide the documents (contracts, invoices, etc.) by which you could support the use
of such amount of cash.

Please provide the above mentioned information and/or documents by 21-07-2021 by choosing
one of the below specified ways of provision of information (documents) which is convenient to you:

• You may send information by a message in the internet bank;
• You may send information and documents to the e-mail address: [email protected] from the
e-mail address which you have indicated to us when providing your contact details. You can
check or change your e-mail address indicated to us on Swedbank’s Internet Bank, under
“Contact details”
• You may bring signed information (documents) to any Swedbank’s customer service branch.
Note! Note that we currently provide services at Swedbank branches only if you have
registered for a consultation in advance.
https://www.swedbank.lt/private/home/more/appointmentsIf you fail to submit to us the requested information (documents) by 21-07-2021 we will have no
possibility to provide to you all or part of services, i.e. from this date, on any of 5 (five)
business days following this time limit, we will restrict your access to the account(s) opened in
your name with Swedbank. In such case, you will not be able to make card-based payments,
withdraw cash from and deposit cash to ATMs, make credit transfers and carry out other
operations using Swedbank’s App and Swedbank internet bank (you will be able only to view
the information there), in addition, you may be denied access to other services. You will be
able to use the aforementioned services again when you submit the requested information
(documents). If you fail to submit the requested information (documents), Swedbank shall also
have the right to terminate business relationships with you.
We are requesting the above specified information (documents) on the following legal grounds:
- Law of the Republic of Lithuania on the Prevention of Money Laundering and Terrorist Financing
(Article 9);
- Guidance for the financial market participants aimed at the prevention of money laundering and/or
terrorist financing approved by Resolution No 03-15 of the Board of the Bank of Lithuania of 30
January 2020 (paragraphs 51-58);
- General Conditions for Dealing with and Servicing of the Customers of the Bank (item 3.4.8).

You can get acquainted with the General Conditions of Dealing with and Servicing the Customers of
Swedbank on the internet website of Swedbank at the address: www.swedbank.lt and at the customer
servicing branches.

We are asking to provide the above referred information (documents) in observance of legal acts and
in implementing the principle ‘Know Your Customer’. In implementing the above referred principle,
banks must update the information about their customers and carry out the continuous monitoring of
business relationships of customers, including the investigation of operations (transactions), in order to
ensure that the operations and transactions being carried out correspond to the information available
to the Bank about the customer, his business (types and nature of business, nature of transactions,


„Swedbank“, AB
Konstitucijos pr. 20A, 03502 , Vilnius,
Lithuania
Tel. +370 5 268 4444, fax +370 5 258 2700
S.W.I.F.T. HABALT22
The Bank is registered with and data on it
stored at Lithuanian legal person‘s registry,
whose keeper is VĮ Registrų centras
Company code 112029651
VAT payment code LT120296515
www.swedbank.lt

business partners, territory of operations, etc.), type of risk and information about the source (origin) of
funds. More information about the prevention of money laundering and/or terrorist financing and the
principle ‘Know Your Customer’ is available on the internet website of Swedbank at the address:
www.swedbank.lt/private/prevention.

Thank you in advance for the time devoted by you. We guarantee that the information provided by you
will be properly protected like any other information which constitutes the bank secret.

If you have any questions, please don’t hesitate and call us at 1884 (+370 5 268 44 44).

Respectfully
Your Swedbank
 
I guess decision is already made?
Actually it's looks like for a more or less standard request for compliance.

Timeline a bit tiny, but still possible.

On the your contragent list I see crypto related companies.

Don't know if swedbank is allow to operate with crypto by their clients. If yes - just give information requested and continue to use account.

If swedbank don't like crypto - account would be closed.
In any way I don't see any other solutions except disclose crypto nature of transactions and leave up bank to decide.
 
where to get documents?
links to the terms in platforms, screenshots and another information related to the transaction.
Because there is no contract\invoices for such operation you should give write explanation about transaction and show flow of money in way how it could be proved.
and how to explain with documents the cash withdrawals
For cash withdrawals you could show some receipts how you spend cash and say that it's for personal savings and current expenses.
 
This situation will only lead to more troubles later on. Clean out the account carefully as they may freeze it before their deadline. Then advise them that you need 3 months to collect the info they need . There is no way a US bank would ask for such information for an existing account.
 
"This situation will only lead to more troubles later on"
What do you mean?

i would have to spill my guts out just to let them decide whether to close or not my account
who is from Europe and had this bs before
is it worth my time and effort?
 
The request isn't uncommon, especially if you are conducting five-figure transactions through a traditional bank. It's pretty much standard now as soon as you do anything out of the ordinary ("ordinary" meaning a regular monthly salary, house loan, and some savings).

If Swedbank Lithuania is known for tolerating crypto, this shouldn't be a problem. Just go through each question and answer to the best of your abilities.

If you suspect that they will not tolerate crypto transactions, you have a choice: either clean out the account and run away, or explain the situation, provide all the documents/information, and then commit to not transacting in crypto with Swedbank again. Then in the future, if you put a crypto-friendly EMI or bank between yourself and Swedbank, you are less likely to run into trouble.
 
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Reactions: rowena
This is very normal compliance these days. You should give time and answer all questions, but probably they will close your account.
I would advise same. Withdraw all funds and only then start answering questions
 
i guess everything i say and produce will be used against me
Is it anything illegal you do with them? If yes, sure problems will come.

If you just do some crypto and bank don't allow such activity its nothing bad, but just bank's policy. You not obligued to know all bank's internals. Its a just a business where you dont meet each other expectations.
Words calling aml/tf just scare thing that should force you to give them docs, but not so serious if it not real aml in fact.
 
holy c.
well as someone said normal nowadays but still not so common.
what really surprises me that they waste time KYCing basically an account holder which barely makes his ends meet...transacting amounts such as 20k, 30k...basically 1 day of port taxes for a midaged yach holder or 1 evening of bottle service at a random club in St.Tropez
don't know what bank people smoke going after these microaccounts but this just confirms perpetual misery and cents counting Europe got in

As for the solution...this is probably caused by some KYC/AML software going a bit bezerk so as someone said if possible empty the account preferibly by wiring to your own account in a reputable bank or wiring to a reputable company as Google to buy some credits for... anything :D
Then as someone said, ask a time extension to "gather documentation", in the meantime write them by your lawyer to close the account citing some presumed breach of GDPR or such or if there is anything negative in press about them cite that you are not comfortablle working with a bank with tainted reputation and ask for account closure asap.

Once they start bugging unless you are sure that you are 100% legal and your lawyer can have a talk with them, they won't stop bothering you (impossible to advice here since not sure if you are ok with spilling your guts out as you said)
 
holy c.
well as someone said normal nowadays but still not so common.
what really surprises me that they waste time KYCing basically an account holder which barely makes his ends meet...transacting amounts such as 20k, 30k...basically 1 day of port taxes for a midaged yach holder or 1 evening of bottle service at a random club in St.Tropez
don't know what bank people smoke going after these microaccounts but this just confirms perpetual misery and cents counting Europe got in

As for the solution...this is probably caused by some KYC/AML software going a bit bezerk so as someone said if possible empty the account preferibly by wiring to your own account in a reputable bank or wiring to a reputable company as Google to buy some credits for... anything :D
Then as someone said, ask a time extension to "gather documentation", in the meantime write them by your lawyer to close the account citing some presumed breach of GDPR or such or if there is anything negative in press about them cite that you are not comfortablle working with a bank with tainted reputation and ask for account closure asap.

Once they start bugging unless you are sure that you are 100% legal and your lawyer can have a talk with them, they won't stop bothering you (impossible to advice here since not sure if you are ok with spilling your guts out as you said)

Some EU banks are closing accounts for regular people who are transacting 500-1000 EUR .. So it's unfortunately nothing unusual.
 
"This situation will only lead to more troubles later on"
What do you mean?
Read my next sentence: "Clean out the account carefully as they may freeze it before their deadline"

i would have to spill my guts out just to let them decide whether to close or not my account
who is from Europe and had this bs before
is it worth my time and effort?
Agree, odds are account is lost but you can still show good faith by replying to their demands and offer alternative solution. In case your original assessment was wrong, although unlikely.
 
Last edited:
It's very normal. If everything is legit, it will be fine. If you're doing something fishy, they'll probably close the account.
I took some loans and I sent some cash to earn interest
sold an apartment in Estonia, money went to swedbank
sent proof of sale - all was ok
then increased transfer limit to 60k
sent money ~5k every second month to my Ukrainian bank (swedbank is not interested in that)
so I think it is about crypto stuff, same issue had couple of years ago with siaulai bank
 
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so that's the main reason for crypto existence basically. those banks and their "great service" is not what we want, they'll so going to be closed down when have no more customers ... only banks who transition to being a company that provides crypto services, will remain in business IMHO. But that's probably a 20-25 years projection (full new generation to replace older generation, people born in 1990s and 2000s will be in charge of top banks/corporations at that time, Pokemon fans will become big boys who rule the world... I wonder how that world will look like, definitely a lot of Minecraft, Crypto, and Pokemons involved :D)
 
  • Haha
Reactions: newNomad
I think also it's crypto related.
Was also called once myself by a local branch who enquired about ultramicro transfer of 5k (i.e. 0.005 million euro) to a trading platform (which by the way does not even allow crypto)
I explained it's forex trading and no crypto at all. They had no more questions
 
Dear Customer,
Please be advised that on 22-07-2021 we blocked the account No LT69696969696969 opened
with Swedbank in your name, because you have failed to provide to us the requested information
(documents) by the specified time limit.
Legal grounds for the blocking of accounts:
- Law of the Republic of Lithuania on the Prevention of Money Laundering and Terrorist Financing
(Article 9(18), Article 18);
- General Conditions of Dealing with and Servicing the Customers of Swedbank (items 3.4.8, 4.3.1
and 11.1.5);
- Payment Services Provision Conditions of Swedbank (item 7.2.1).
You may get acquainted with the General Conditions of Dealing with and Servicing the Customers
of Swedbank and with the Payment Services Provision Conditions of Swedbank on the internet
website of Swedbank at the address: www.swedbank.lt and at the customer servicing branches.
Please be reminded that we are asking to provide the above referred information (documents) in
observance of legal acts and in implementing the principle ‘Know Your Customer’. In implementing
the above referred principle, banks must update the information about their customers and carry out
the continuous monitoring of business relationships of customers, including the investigation of
operations (transactions), in order to ensure that the operations and transactions being carried out
correspond to the information available to the Bank about the customer, his business (types and
nature of business, nature of transactions, business partners, territory of operations, etc.), type of
risk and information about the source (origin) of funds. More information about the prevention of
money laundering and/or terrorist financing and the principle ‘Know Your Customer’ is available on
the
internet
website
of
Swedbank
at
the
address:
https://www.swedbank.lt/private/home/more/preventionIf you have any questions, please don’t hesitate and call us at +370 5 268 4444.
Note! Note that we currently provide services at Swedbank branches only if you have registered for
a consultation in advance. pageTitle
Respectfully,
Your Swedbank
 
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