General Requirements

Any LHV applicant must have an adequate AML/compliance framework in place. LHV’s Compliance team will review each applicant to ensure:

• The applicant is properly 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) is in accordance with the complexity of the business modelThe maturity of its operations (processes, systems, staff and relevant experience) is in accordance with the complexity of the business model
• It employs an independent Money Laundering Reporting Officer with sufficient experience;
• The applicant has management/directors with trustworthy backgrounds and sufficient experience;
• The acceptability of the risk profile of the applicant and any linked entities/persons (e.g. shareholders and directors);
• Acceptability of risk profile of clients/product(s); and
• The 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 cryptocurrency / virtual asset service providers, non-bank financial institutions and other financial intermediaries

Applicants’ framework for onboarding and monitoring these types of clients must be fit for purpose and not fall below those of LHV. When onboarding the businesses types as a minimum, these KYC principles should be applied.