We Know Our Customer

We ask for your personal and contact details, information on your income and workplace, details of company ownership and control, information about your main operations and objectives and details about your ID document(s). We might also ask you to submit bank statements for earlier periods.

We ask for information about transactions and other activities so we can detect unusual or suspicious transactions that could point to fraud. We’re also obliged to monitor transactions for the prevention and obstruction of money laundering and terrorist financing. This protects your account against potential fraud and ensures a secure banking service.

We need to be satisfied that the information you provide us with is correct, which is why we ask you to submit additional documents where necessary – precisely because we can’t always rely on data from transactions or registers, but can be satisfied on the basis of documents or data provided to us.

Click here for more information on our risk appetite in regard to the prevention of money laundering and terrorist financing and the implementation of international sanctions.

Banks being obliged to keep up to date on what their clients are doing isn’t a one-off thing. A bank can gain a lot of the information it needs about a client in the course of its day-to-day services (e.g. when the client performs transactions or takes out a loan), but there are certain data which the law requires to be updated and that the bank can’t obtain without asking the client. Such data include the client’s contact address, their tax residency and the details of where they work.

Updating client data can’t be an automated process based solely on transactions and registers, but has to be done by communicating with the client, if for no other reason than to enable the bank to make sure the data it receives are correct (and valid).

In addition to the regular updating of data, a bank may contact a client about a transaction they’ve performed. There may be several reasons for this: for example, the transaction may differ noticeably from those the client normally makes, or in the case of cross-border payments, the bank processing the transaction may be asked to clarify it.

We have to collect information on actual beneficiaries so as to comply with our obligations under the Money Laundering Prevention Act and the Tax Information Exchange Act.

An actual beneficiary, also known as a beneficial owner, is a natural person who ultimately controls another natural or legal person or for whose benefit, to whose advantage or on whose behalf a transaction or operation is performed.

Actual beneficiary status can be endowed by either the direct or indirect exercising of control. Direct control is when a natural person holds more than a 25% share in a company. Indirect control is when more than a 25% share in a company is held by another company controlled by a natural person or by several companies controlled by the same natural person.

The actual beneficiary of a private client’s bank account is the person who holds or controls the account and directly benefits from it. If the account is actually controlled by someone else, the bank should be informed of this as soon as possible.

Guidelines on identifying actual beneficiaries can be found on the website of the Ministry of Finance.

TEKSA is a database of actual beneficiaries which enables us to check on an ongoing basis the conformity of the beneficiaries submitted to us and, if a discrepancy is found, to ask companies to check which databases have yet to be updated and to update them accordingly. If they don’t, we as a bank are obliged to file a discrepancy report with the Commercial Register, which then flags up the company’s data in TEKSA. We have the right to terminate the customer relationship should we choose to do so.

We ask for the following details regarding actual beneficiaries: name; personal ID code; the country in which the ID code was issued, or date and country of birth; tax residency; tax identification number; e-residency; residential address; and how the company is controlled and the size of the share.

To prevent misunderstandings, we ask you to provide accurate information and to inform both us and the Commercial Register if there is any change in the actual beneficiaries.

Any non-resident looking to establish a business relationship must have a strong link to Estonia. When an account is opened, the links mentioned below are assessed collectively – and bear in mind that meeting a single criterion may not be considered enough to establish a business relationship in all situations.

In the case of a legal entity, a strong link to Estonia means:

• financial activities that are connected to the country (e.g. the company’s permanent place of business or employees are in Estonia);
• its main partners are in Estonia;
• it provides a product or service aimed at the local market (e.g. an Estonian-language online store);
• it has property in Estonia or the company’s operations are related to property; and/or
• another significant and verifiable link which explains why the company needs a bank account in Estonia.

Where individuals are concerned, we count the following as strong links to Estonia:

• a valid employment contract or an employer’s written confirmation of registration of short-term employment in Estonia;
• a certificate from an educational institution confirming that the person is studying in Estonia (which must be valid for at least six months and be no more than one month old);
• existing property in Estonia whose upkeep costs are paid from their bank account or rent from which is paid into their bank account; and/or
• another significant and verifiable link which explains why the company needs a bank account in Estonia.

The following are classified as non-residents:

• Individuals whose permanent place of residence is not in Estonia or who have been issued with a residence permit lasting less than one year
• A company registered abroad or an Estonian company controlled by a person who isn’t a resident of Estonia (i.e. the company is under the ownership of a non-resident beneficial owner or owners to the extent of more than 25% of the company being controlled by one or more non-residents in any manner, or if the majority of the company’s management consists of non-residents)

PEP stands for ‘politically exposed person’ and means an individual who is or has been entrusted with prominent public functions in the last 12 months or who is a member of such a person’s family or a close associate of the person.

We’re obliged to identify PEPs whose public roles warrant heightened attention. PEP status doesn’t mean we won’t open a bank account for them, or that we’ll restrict their services, just that we’re obliged to adopt enhanced due diligence measures in regard to them.

The PEP’s spouse (or person treated as equivalent thereto), children and parents and their spouses (or persons treated as equivalent thereto) qualify as members of the PEP’s family. Close associates include individuals who own a business or any form of legal entity with the PEP or have a close business relationship with them.

A full list of the positions that qualify as PEPs can be found on the Eesti Pangaliit website.

You can update your details quickly and easily in our Internet bank, at any of our branches or by contacting your personal account manager (whose contact details can be found in your online bank).

Banks are obliged to verify the origin of a client’s assets so as to understand how the customer came by the assets or where the funds used in a particular transaction were sourced from.

Clients must provide evidence of the legal origin of assets in order to clarify the financial objective of a related transaction and its links to actual economic activities.

To do this, we ask that you respond to any and all enquiries and attach documents confirming the origin of your assets. These can be bank statements, tax returns, invoices, real estate sales contracts, loan agreements, inheritance documents, etc.

In our price list, we apply a special price for opening an account for clients operating in specific fields of activity, since they’re subject to enhanced due diligence measures.

These fields of activity are as follows:

• Manufacturing, purchase and/or sale of weapons and/or ammunition (excl. hunting and sports clubs and shooting ranges)
• Gambling services
• Currency exchange and pawnshops
• Manufacturing of military vehicles
• Provision of cash transport services
• Crowdfunding platforms and provision of instant loans
• Mining
• Buying and/or wholesaling of precious metals, precious stones and precious-metal products
• Bailiff services
• Credit and financing institutions

The legality, confidentiality and security of client data are guaranteed in their processing. The collection of such data is limited to the minimum required to fulfil the purpose for which we intend to process the data. Access to the data is granted to employees who have completed the appropriate training and who are authorised to process the data only to the extent necessary for the performance of their duties. Only employees who require access to the data for the fulfilment of their duties are granted such access. The legality of the processing of client data is monitored by the Coop Pank Group’s data protection specialist.

Feel free to review our principles of processing client data.