Limited foreign payments

Banks are obligated to implement the international sanctions established by the European Union (EU) and the United Nations (UN). Information concerning international sanctions and a general overview of this field along with references to relevant legislation and guidelines are available here: https://vm.ee/en/sanctions-arms-and-export-control/international-sanctions and https://www.sanctionsmap.eu/#/main.

International sanctions must be implemented when establishing a client relationship and also during the course of the relationship. Inspections related to sanctions affect both domestic as well as foreign payments in the bank. In practice, this may mean that instant payments subject to inspection cannot be processed as an instant payment, the payment is processed slower than usual and/or further information is requested concerning the payment either by the bank or at the request of the correspondent bank or the bank of the other party to the transaction. Additional information and documents may be requested regarding the transaction in order to eliminate any suspicion concerning the violation of sanctions. Depending on the restriction, the bank could be obligated to block or reject the transaction, and the same applies to the bank of the other party to the transaction or the correspondent bank.

In addition to the sanctions established by the EU and the UN, other countries can also establish sanctions and restrictions on an individual basis. Based on the general practices of international banking, Coop Bank also applies U.S. OFAC sanctions on a risk basis. More information on these can be found here: https://home.treasury.gov/policy-issues/financial-sanctions/specially-designated-nationals-and-blocked-persons-list-sdn-human-readable-lists

Special attention is paid to dual-use goods in relation to most sanctions. These are goods, including software and technology, which can be used for both civil and military purposes, including goods that can be used for both non-explosive uses and assisting in any way in the manufacture of nuclear weapons or other nuclear devices. Council Regulation (EC) No 428/2009 of 5 May 2009 setting up a Community regime for the control of exports, transfer, brokering and transit of dual-use items regulates the nature of dual-use goods.

Due to international sanctions and other rules applicable in banking, it is important when concluding transactions with parties in third countries (i.e. countries that do not belong to the European Union and are not member states of the European Economic Area) that the payment details of the counterparty include their address and the description of the payment correctly reflects the content of the transactions, and also for business clients to be aware of any restrictions established on the countries where they conduct their business activities in, as violating restrictions either intentionally or due to a lack of knowledge could inter alia bring about financial damage (e.g. due to delays in payments or blocking payments).

The European Union establishes sanctions with regulations that are mandatory for performance for the member states and the legal persons located in the Union and are directly applicable. Domestically, the field of sanctions is regulated in the International Sanctions Act, which provides for the bodies establishing sanctions and their nature, as well as the obligations of persons having specific obligations and the rights of subjects of financial sanctions.

Supervision over banks in the field of international sanctions is exercised by the Estonian Financial Supervision Authority.

The European Union has established several restrictions on Belarus. Further information on these is available on the website of the Ministry of Foreign Affairs and the EU Sanctions Map.

Due to the sanctions imposed as a result of Russia’s military aggression in Ukraine, Coop Pank AS suspended all payments to Russian and Belarusian banks on 8 April 2022. This restriction extends to all subsidiaries of Russian and Belarusian banks that may be registered or operate outside of Russia and Belarus.

Starting from 19 August 2022 Coop Pank AS no longer accepts payments linked to Russia or Belarus. This means that starting from 19 August 2022 it is no longer possible to receive payments in an account opened in Coop Pank AS initiated by:

• Russian and Belarusian banks or other financial institutions or via the subsidiaries of these banks or financial institutions operating in the EU
• Companies founded outside of Russia or Belarus, but of which more than 50% of the owners are from Russia or Belarus
• Companies founded in Russia or Belarus via any other bank or financial institution

Coop Pank AS may also decline to perform a transaction if it identifies a Russian or Belarusian party in the goods supply chain or otherwise involved in the transaction or if the final beneficiary of the goods or service is Russian or Belarusian. As an exception, payments linked to Russia or Belarus will be accepted if they pertain to the national interests of Estonia or humanitarian reasons, such as benefits or pensions. We will also allow our clients, as an exception and for valid reasons, to accept payments related to exiting businesses linked to Russia or Belarus.

Furthermore, Coop Pank AS is not opening new accounts for Russian or Belarusian citizens who do not have a valid residence permit for a Member State of the European Union, the European Economic Area or Switzerland and is not permitting them to perform occasional transactions.

The European Union has imposed extensive sanctions on Russia, Crimea, Luhansk, Donetsk, Hersoni and Zaporižžja Regions in Ukraine. Further information on these is available on the website of the Ministry of Foreign Affairs and the EU Sanctions Map.

Due to the sanctions imposed as a result of Russia’s military aggression in Ukraine, Coop Pank AS suspended all payments to Russian and Belarusian banks on 8 April 2022. This restriction extends to all subsidiaries of Russian and Belarusian banks that may be registered or operate outside of Russia and Belarus.

Starting from 19 August 2022 Coop Pank AS no longer accepts payments linked to Russia or Belarus. This means that starting from 19 August 2022 it is no longer possible to receive payments in an account opened in Coop Pank AS initiated by:

• Russian and Belarusian banks or other financial institutions or via the subsidiaries of these banks or financial institutions operating in the EU;
• companies founded outside of Russia or Belarus, but of which more than 50% of the owners are from Russia or Belarus;
• companies founded in Russia or Belarus via any other bank or financial institution.

Coop Pank AS may also decline to perform a transaction if it identifies a Russian or Belarusian party in the goods supply chain or otherwise involved in the transaction or if the final beneficiary of the goods or service is Russian or Belarusian.

As an exception, payments linked to Russia or Belarus will be accepted if they pertain to the national interests of Estonia or humanitarian reasons, such as benefits or pensions. We will also allow our clients, as an exception and for valid reasons, to accept payments related to exiting businesses linked to Russia or Belarus.

Furthermore, Coop Pank AS is not opening new accounts for Russian or Belarusian citizens who do not have a valid residence permit for a Member State of the European Union, the European Economic Area or Switzerland and is not permitting them to perform occasional transactions.

Coop Pank AS processes payments pertaining to Crimea, Luhansk, Donetsk, Hersoni and Zaporižžja Regions to the extent that such actions do not violate the international sanctions. Processing of such payments takes longer than usual.