Onboarding

Valid from 30.01.2020

It is essential that any LHV applicant has an adequate AML / compliance framework in place. LHV Compliance will review each applicant in order to ensure:

• If required, it is correctly regulated to conduct all current and envisaged business;
• That its risk-based AML / compliance framework (e.g. policies, human resources, technical systems) is adequate;
• The maturity of its operations (processes, systems, staff and relevant experience) are in accordance with the complexity of the business model
• It has an independent Money Laundering Reporting Officer of sufficient experience;
• It has management / directors with trustworthy background and sufficient experience;
• Acceptability of risk profile of the applicant and any linked entities / persons (e.g. shareholders directors);
• Acceptability of risk profile of clients / product(s); and
• Acceptability of AML / compliance culture.
  
  

Crypto-currency

Applicants that process crypto-currency linked transactions will undergo additional review to ensure:

• Acceptability of coin offering;
• Acceptability of coin listing criteria; and
• Crypto-specific transaction monitoring software is in place.

Applicants that service crypto currency / virtual asset service providers, non-bank financial institutions and other financial intermediaries

Applicants framework for onboarding and monitoring of these type of clients must be fit for purpose and must not fall below those of LHV.

When onboarding the businesses types as a minimum, these KYC principles should be applied