Customer Data

We collect customer data to provide better services, but also to fulfil our legal obligations and ensure security

We ask questions about contact details, citizenship, place of residence, area of activity, etc.
From time to time, we ask customers to provide or update information concerning their activities.
We regularly update customer data based on the information received from the Population Register.
If necessary, we ask for additional details and documents constituting the basis for transactions (e.g., origin of funds, sales, lease and supply agreements, documents related to the goods, etc.), and data or documents regarding the counterparty, actual beneficiary, or any other person involved in or related to the transaction.

If your details have changed please update them in our database as soon as possible. This means that we can always contact you quickly whenever necessary.

My data

Please log in to view and update your data.
If you don’t use the Internet Bank, you can fill in the data in a PDF form, sign it digitally and send to info@swedbank.ee

Why do banks ask their customers to provide information about them?

Relationship between a bank and its customers is based on mutual trust. We care about our customers’ trust; we, therefore, periodically publicly announce our financial results and other performance reports. Accordingly, we ask our customers to provide certain information about them as well.

Provision of information is important for several reasons. First, banks must comply with very strict legal requirements which oblige them to implement the ”Know Your Customer (KYC)” principle. Implementation of this principle is related to application of international measures aimed at prevention of money laundering and terrorism financing. Banks must ensure that their infrastructure is not abused by malicious entities or by persons who pose threat to others.

Another important reason is that banks care about their customers’ security and the security of their accounts. With up-to-date details available, we can ensure safety of accounts more easily, prevent illegal actions by fraudsters, stop suspicious transactions and thereby protect our customers from financial losses.

Do these requirements apply to other banks as well?

Which institutions are authorised to receive the details I provide?

All of the data you provide us is protected by strict security and confidentiality rules.

We disclose customer data to third persons only if we have received the customer’s written consent or if the disclosure of data is required of us pursuant to law (e.g. a notary, the police, the State Revenue Service and Customs Board).

Information is not collected with the purpose to immediately forward it to other institutions. Information you provide is stored responsibly. In certain cases, when this is necessary, authorised institutions (law enforcement, security provision, etc.) are entitled to address banks and request the provision of information about a customer. In such case, the bank, in accordance with laws, will be obliged to provide such information.

How do you ensure that my data is in safety?

Banks have a duty to guarantee secrecy of customer’s identity, accounts, deposits and transactions
Information regarding a customer and their transactions acquired by the bank through provision of financial services under the relevant contract is non-disclosable information
The bank may disclose such information only to customers themselves or to their representatives except in cases laid down in the Law on Credit Institutions – to government authorities and other persons, as set forth by this law

What could happen if I refuse to submit the declaration/questionnaire?

Who are “politically exposed persons”?

What is tax information exchange?

The CRS (Common Reporting Standard) and FATCA (Foreign Account Tax Compliance Act) require us to ask from all of our clients about their tax residency and share information with the Tax and Customs Board if our client is a foreign tax resident. This is primarily designed to prevent tax evasion. Information exchange concerns natural persons and legal entities alike.

FATCA

Applicable to financial institutions all over the world.
We must identify US tax residents.
The Tax and Customs Board shares the information with the Internal Revenue Service of the US.

More about FATCA:

FATCA rules

Website of the Ministry of Finance

Website of the Internal Revenue Service of the US

CRS

Applicable mainly to the Member States of the EU and OECD.
We must identify tax residents from the respective countries.
The Tax and Customs Board shares the information with the Tax Board of the respective country.

More about CRS:

Website of the Ministry of Finance

Website of the OECD

What languages can be used to fill in the declaration/questionnaire?

Which legislation regulates the KYC principle, incl. data processing routines?

Why do banks update customer data based on external registers?

What should I do if my name has changed?

If the name change is registered in Estonia, the bank will generally change your name based on the data in the Population Register. If you haven’t received a notification that your name has automatically changed, please let us know about your name change by writing us a bank message or booking an appointment and visiting one of our branches.

Nothing will change for you regarding the use of your account(s) and services.

We recommend replacing your card in case your name on the card and booking details (hotel, rental car) don´t match. If your card details have changed, please update it in bookings and subscriptions as well.

We also recommend that you notify the persons and authorities, who make transfers to you, of your new name/name form. Transfers to your old name can be made within 6 months. After 6 months, transfers can only be made to a new name.

If the name change is not registered in Estonia, please provide the necessary documents proving the name change. You can do so by booking a time beforehand and visiting one of our branches.

How can I make transfers to a person whose name contains foreign letters or symbols that the computer keyboard does not have?

General information about international sanctions

International sanctions form an essential foreign policy tool that helps maintain or restore peace, international security, democracy, and the rule of law, while following the human rights law and other international laws. Sanctions are imposed by states (such as the US and the UK), international organisations (such as the UN) and supranational bodies (such as the EU). International sanctions are imposed against entire states, as well as natural and legal persons that violate human rights, commit ethnical, territorial conflicts, support terrorism, or violate other international norms and principles.

International sanctions take various forms based on their objective (e.g., to prevent armed conflict, counter terrorism). Types of sanctions include sanctions imposed on individuals (e.g., travel ban, asset freeze), targeted goods and services (e.g., arms embargoes or proliferation-related goods, dual-use goods), core economic sectors (e.g., oil or financial sectors), or an entire country (e.g., North Korea).

International sanctions implemented by Swedbank

UN. All UN member states are obliged to accept and carry out resolutions passed by the UN Security Council.
- UN Security Council’s sanction regimes: https://www.un.org/securitycouncil/sanctions/information
EU. The EU Council establishes sanctions by regulations that have direct effect to all member states.
- EU sanction search: https://www.sanctionsmap.eu/#/main
Based on the financial sanctions policy of Swedbank Group, Swedbank implements the relevant US and UK financial sanctions.
- By implementing these, the Bank keeps and maintains relations with banks in the US and the UK jurisdiction and provides payments and other products or services in USD/GBP to persons registered in the US/UK and their customers.
  - US sanction regimes: https://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx
  - US sanction search: https://sanctionssearch.ofac.treas.gov
  - UK sanction regimes: UK sanctions regimes - GOV.UK
  - UK sanction search: https://search-uk-sanctions-list.service.gov.uk

Swedbank considers both correspondent bank requirements as well as its own risk appetite. Therefore, Swedbank does not engage in actions that directly or indirectly circumvent the financial sanction prohibitions, correspondent banks, or internal decisions.

Types of financial sanctions implemented within Swedbank

Similarly to other financial institutions, Swedbank implements international financial sanctions as stipulated in § 14 of the International Sanctions Act.

The main types of financial sanctions imposed within Swedbank are as follows:

Targeted asset freeze. Swedbank has an obligation to freeze funds, i.e., not make funds available to persons blocked by the EU. In case of sanctions imposed by the US and the UK, Swedbank rejects transactions or declines products or services to subjects listed in OFAC SDN or OFSI.
Arms’ embargoes or restrictions on dual-use goods and technology for military purposes (defence sector). Swedbank is obliged not to participate in the provision of financial assistance related to these goods or related services.
Core economic sector sanctions (financial, energy sector). Swedbank provides neither restricted financial services (e.g., loans, credit, deals with financial instruments), nor does it participate in transactions related to prohibited activities (e.g., restrictions on provision of goods or services related to the oil sector).

It is important to mention that the asset freeze and some sector-specific restrictions also apply to entities that are owned or controlled, directly or indirectly, by designated persons. While those entities may not be designated or included in the sanction lists, the same financial sanctions are applicable to them and need to be implemented by Swedbank.

Restrictions related to Prohibited Countries and Territories

Considering the international sanctions, Swedbank’s decisions, requirements of correspondent banks, as well as the current geopolitical situation, Swedbank has the obligation and the right not to execute any direct transactions (including cash and non- cash payments, card payments) in any currencies in its customers' accounts if they are directly related to the following countries or regions (hereinafter referred to as the Prohibited Countries):

Afghanistan
Crimea
Cuba
Iran
North Korea
Republic of Belarus
Russian Federation
Syria
The territories of Ukraine's Donetsk, Luhansk, Kherson, and Zaporizhzhia regions not controlled by the Ukrainian government
Venezuela

Swedbank also considers indirect transactions as unacceptable (including cash and card payments) in its customers' accounts that are connected to the above-mentioned Prohibited Countries.

All transactions identified in customers' accounts that have any direct and/or indirect connection with Prohibited Countries and which may be deemed unacceptable, will be assessed on an individual basis. Examples of situations that considered unacceptable are as follows:

Transactions with or connected to natural persons residing and/or operating in Prohibit ed Countries.
Transactions with or connected to legal entities established and/or operating in Prohibited Countries.
Transactions with underlying export or import of goods or services, funds, or destination are connected to a Prohibited Countries.
Deposits of cash derived from the income obtained in a Prohibited Country, for example for the sale or rent of property, sold goods and/or services, dividends or funds related to employment in companies and/or organisations established and/or operating in Prohibited Countries.

We would like to draw your attention to the fact that the term of executing payment transaction may be extended or payment may be blocked or frozen by Swedbank or by other banks that participate in the execution of a transaction (correspondent bank, bank of beneficiary or sender). Therefore, customers should always evaluate potential international sanctions risks.

In addition to the above restrictions, access to the Bank’s products and services might be limited (including initiation/performance of the transaction) when servicing a customer that performs the transactions described above.

Recommended preventive measures

International sanctions imposed by the EU (including implemented UN sanctions) apply within the EU territory and to all EU persons inside or outside the EU territory. Thus, both financial institutions and their customers are obliged to comply with the EU sanctions.

As a low-risk bank, Swedbank expects its customers to be aware of their business exposure to international sanctions, in order to avoid measures which could negatively affect their activities.

Each customer must assess potential international sanction risks when involving themselves in business transactions. The international sanctions are generally widely publicised, and customers, especially those who operate internationally, must understand and adhere to relevant international sanctions. Therefore, customers must consider business activities that could be exposed to international sanctions, and take appropriate risk mitigation steps as follows:

Check, which UN, EU, UK or US sanctions, as well as local (e.g., EE) sanctions apply to the particular country.
Perform due diligence checks on their partners and customers.
Familiarise yourself with the due diligence checks of your partners and customers.
When making payment transfers, please assess whether the payment complies with international sanction requirements; make sure you have the documented proof (e.g., cooperation agreement, agreement between the parties participating in goods transportation, invoices, waybills, references of goods, certificates of origin, primary buyer, final beneficiary, etc.), and be ready to provide it to Swedbank.

The information provided above is not comprehensive, and customers are advised to consult with competent authorities or seek independent legal advice in case of questions related to the implementation of international sanctions.

More information on the EU sanctions is available on the following websites:

Ministry of Foreign Affairs: https://vm.ee/en/sanctions-arms-and-export-control/international-sanctions

Financial Intelligence Unit: https://fiu.ee/rahvusvaheline-finantssanktsioon/rahvusvaheline-finantssanktsioon

Tax and Customs Board: Customs clearance in the context of the war in Ukraine | Estonian Tax and Customs Board