Due diligence questions for a Latvian company

Basic information that is requested first:

  1. Completed Rietumu Banka forms (set of documents for a legal entity).
  2. Copies of identity documents of Members of the Board1 and the beneficial owner(s).
  3. Documents confirming the ownership structure2.

Client characteristics, extent of request for initial additional information:

Company Beneficial owner(s) Request for additional information
Publicly-known company with good reputation
and/or
Publicly-known company with significant economic value
Beneficial owner is a citizen or non-citizen of LR or Beneficial owner has a significant link to LR -
Newly-established company Beneficial owner is a citizen or non-citizen of LR or Beneficial owner has a significant link to LR 1. Documents confirming wealth, past experience of the beneficial owner.
2. Business development plan, business model presentation.
Other Beneficial owner is a citizen or non-citizen of LR or Beneficial owner has a significant link to LR 1. Documents confirming wealth, past experience of the beneficial owner.
2. Account statement for the last 6 months from a financial institution where the basic cash flow takes place at the time of application.
3. Documents on key business partners that may affect the client’s exposure to AML/CFT and sanctions risks, e.g. in terms of geography, industry, etc.3
Other Beneficial owner is not a citizen or non-citizen of LR and does not have a significant link to LR 1. Documents confirming wealth, past experience of the beneficial owner.
2. Account statement for the last 6 months from a financial institution where the basic cash flow takes place at the time of application.
3. Documents on key business partners that may affect the client’s exposure to AML/CFT and sanctions risks, e.g. in terms of geography, industry, etc.3
4. Documents confirming the company’s operations in Latvia and related expenses, such as office maintenance cost, infrastructure in place, etc.

Additional targeted questions, taking into account the circumstances set out below:

Cooperation partners are from RU or BY or other high-risk jurisdiction 1. Sanctions policy (internal control system).
2. Results of sanctions screening.
3. List of commodity codes if the nature of cooperation with the partners involves trade or movement of goods.
4. Economic documents involving said partners, for example, contracts, contract specifications and annexes.
5. Set of documents on a specific shipment of goods or provision of a service involving said partners, for example, invoices, acceptance certificates, transportation documents, declarations.
Cooperation partners include companies from RU or BY, or other high-risk jurisdiction, that are owned by (affiliated with) the beneficial owner 1. Sanctions policy (internal control system).
2. Results of sanctions screening.
3. List of commodity codes if the nature of cooperation with the partners involves trade or movement of goods.
4. Economic documents involving said partners, for example, contracts, contract specifications and annexes.
5. Set of documents on a specific shipment of goods or provision of a service involving said partners, for example, invoices, acceptance certificates, transportation documents, declarations.
6. Account statement of the affiliated company for the last 12 months from a financial institution where the basic (business-related) cash flow takes place.
Source of funds includes loans, investments, capital transfer or other transfers from a company affiliated with the beneficial owner The affiliated company’s account statement for the last 6 months from a financial institution where the main (business-related) cash flow takes place.

1 For those Members of the Board who will have signatory rights at Rietumu Banka.
2 If this is impossible to determine from public registers.
3 If the type of economic activity of the main business partners indicated is appropriate to the nature of cooperation with the client and the partners are publicly known, submission of such documents is not mandatory as sufficiency of the information is documented during due diligence.

Terms used in this questionnaire:

Significant economic value – the significance of economic value can be evidenced by the company’s profits, positive equity. Such information is obtained from the annual report. There have to be financial statements for two consecutive years, confirming the company’s economic activity over this period.

BY – the Republic of Belarus.

Newly established company – a company registered within the last 12 months or a company registered more than 12 months ago that has not commenced economic activity during this period, as evidenced by annual report data.

LR – the Republic of Latvia.

Citizen, non-citizen of LR – a person holding a basic identity document issued by the Republic of Latvia (passport, ID card).

Beneficial owner - a natural person who is the owner of or who controls the client, a legal person or legal arrangement; as regards legal persons – a natural person who owns, in the form of direct or indirect participation, more than 25% of the capital shares or voting stock of the legal person or who directly or indirectly controls it; as regards legal arrangements – a natural person who owns or in whose interest the legal arrangement has been established or operates, or who directly or indirectly exercises control over it, including who is the founder, the trustee or the supervisor (manager) of the legal arrangement.

Significant link between the beneficial owner and LR – a residence permit issued by LR, tangible assets (real estate), employment, kinship, the person owns another company carrying on business.

Documents confirming wealth / past experience of the beneficial owner – professional experience may be evidenced by long-term work experience in the relevant field (CV, including LinkedIn, or an equivalent document), a certificate, a diploma, publicly available information, including but not limited to:

  1. Statements or extracts from registers or data from public, reliable and independent sources on movable and immovable property, companies, securities and other assets owned by the beneficial owner
  2. Tax returns of the beneficial owner
  3. Statements or other documents confirming information about the beneficial owner’s employment, positions held and remuneration
  4. Documents confirming financial performance of companies owned by the beneficial owner – financial statements showing accumulated profits and decisions on the payment of dividends
  5. Letter of recommendation from another credit institution serving the beneficial owner or from public business partners of the beneficial owner
  6. Information about the beneficial owner, his/her business and wealth available from public, reliable and independent sources
  7. Other documents or information on the beneficial owner’s activities that outline his/her economic and social status

Publicly established good reputation – information available from public sources does not cast doubt on the economic activity of the client, is not contradictory to what is stated in the questionnaires, and does not indicate an increased AML/CFT and sanctions risk.

RU – the Russian Federation.