LHV Risk Appetite

Valid from 05.01.2023

Ethics, compliance with regulations and with the expectations of society are core principles of LHV’s business. High ethical standards also cascade to LHV customers and we expect our customers to value and show similarly high ethical principles, high standards of compliance and risk management. LHV applies strict policies regarding trading with PEP’s, sanctioned counterparties, criminals and persons involved with terrorism. In addition to the common practice of prohibiting payments linked to illegal activities, LHV also prohibits payments linked to the following business activities:

  • Unregulated financial services (where licensing required)
    • Pyramid schemes / multi-level marketing (ML)
    • Hawala
    • Un-licensed FX broker
    • Binary options
    • Get rich quick1 schemes
    • Unlicensed gambling (e.g. provision of services using offshore licence)

  • Crypto-currency
    • Facilitating exchange of anonymous crypto currency
    • Unlicensed facilitation of security tokens (e.g. tokens that have characteristics akin to traditional instruments like shares, debentures or units in a collective investment scheme)

  • Unregulated pharmaceuticals / food supplements (e.g.“nutraceuticals”)
  • Piracy or illegal streaming
  • Counterfeit goods
  • Arms / dual use goods
  • Unlicensed charities
  • Shell companies2
  • Companies formed of Bearer Shares
  • Remittances funded in cash

  • Offshore3 and shell banks
  • Adult services connected to human trafficking; intermediation of prostitution; production, visual broadcasting of pornography or striptease clubs (the approach does not include literature, toys, DVD's, educational or scientific material or dating sites (e.g. Tinder))
  • Business types servicing only high-net worth individuals
  • Fifth-party payments4 & multi-layered MSB arrangements
  • Political / religious organisations engaged in hate speech5

Due to the current geopolitical situation and to mitigate against the risk of evasion of economic sanctions, LHV does not permit its financial intermediary clients to execute transactions related to the Russian Federation or the Republic of Belarus (except in circumstances where a payment relates to an expatriated Russian or Belarussian citizen holding a residency permit in the European Union or the United Kingdom).

The deviation from the LHV risk appetite may result in termination of the client agreement.

1 Proposal to pay high rates of return over a small period in return for a small investment
2 A limited liability entity having no physical presence, no employees or no commercial activity in its registered jurisdiction
3 Jurisdictions listed by the IMF as Offshore Financial Centers and European Commission blacklist - Common EU list of third country jurisdictions for tax purposes
4 LHV client is facilitating payments for its client’s client’s client
5 Promoting harm against or directly attacking or threatening other people