FAQ

Question
Prevention of money laundering and terrorist financing
	Customer identification
	Is it mandatory to obtain from the customer the documents, data or other information necessary to identify the customer? Can data obtained from databases or service providers be used?
	What are the requirements for determining the purpose and intended nature of the customer’s business relationship? Are there cases where the customer is not required to provide this information?
	Should the documents of a legal entity and copies of registration documents collected remotely be notarised or certified by an Apostille? Is an e-signature sufficient to validate these documents?
	Are financial institutions obliged to obtain a copy of the customer’s identification document when the customer is identified in accordance with Article 11(1)(3) of the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing?
	How should financial institutions, when identifying a customer as defined in Article 11(1)(3) of the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing, make sure that a proper identity document was used at the time of the issue of the qualified electronic signature?
	How should financial institutions verify a customer’s citizenship when using their driving licence for identification purposes? Is a driving licence issued in the United Kingdom, which is no longer part of the European Economic Area (EEA), a valid document for a customer’s identification?
	How can a financial market participant authenticate a customer in the physical presence of the customer if, at the beginning of the business relationship, the customer’s identity was established and verified upon receipt of their passport or identity card?
	Is it obligatory to check against public, reliable and independent sources for negative information that can impact the customer’s, its representative’s and beneficiary’s reputation (e.g. if a pre-trial investigation into the customer’s financial crimes is initiated, etc.) during customer identification and verification?
	Do paper versions of documents (e.g. copies of passports, shareholder registers and company’s articles of association, etc.) collected during customer identification have to be stored? Is it sufficient to store only electronic versions of the documents in the customer’s file, according to internal control procedures determined by the financial institution?