Ethics, compliance with regulations and with the expectations of society are core principles of LHV’s business. High ethical standards also cascade to LHV customers and we expect our customers to value and show similarly high ethical principles, compliance standards, and risk management.

LHV applies strict policies regarding trading with Politically Exposed Persons (PEP), sanctioned counterparties, criminals and persons involved with terrorism.

In addition to the common practice of prohibiting payments linked to illegal activities, LHV also prohibits payments linked to the following business activities:

• Unregulated financial services (where licensing is required)

• Providing multi-level marketing (MLM)

• Informal Value Transfer Systems such as Hawala

• Un-licensed FX broker

• Binary options

• Get rich quick schemes (proposal to pay high rates of return over a small period in return for a small investment)

• Facilitating exchange of anonymous crypto currency

• Unregulated virtual/crypto asset exchanges/marketplaces (including entities in jurisdictions where licensing/regulation is not required)

• Crypto ATMs

• Businesses involved with offering or facilitating unregulated ICOs

• Crypto mixers and tumblers

• Provision of gambling services without a licence, or without authorisation in a jurisdiction where authorisation is required

• Financial institutions that lack appropriate measures to approve / monitor the AML compliance programmes of their clients that are obliged entities

• Multi-layered MSB arrangements (a structure in which multiple layers of entities or intermediaries are involved in the provision of financial service)

• Sale of pharmaceuticals/food supplements making unauthorised nutrition and health claims

• Unauthorised distribution of copyrighted material

• Grey market digital goods marketplaces and gambling/betting (businesses operating in the unofficial markets for digital goods, including unauthorized resale marketplaces (e.g., digital key platforms, incl. for video game codes and items) and gambling/betting operators where the stake is monetary, but prizes are digital items (e.g., "skins betting" websites)

• Arms / dual use goods

• Unregulated charities (with no governing national authority)

• Shell companies (limited liability entity having no physical presence, no employees or no commercial activity in its registered jurisdiction)

• Companies with bearer securities or shares exceeding 10% of their capital

• Payment flows initiated via cash deposits

• Shell banks and banks operating via an offshore license

• Adult services connected to human trafficking; intermediation of prostitution; production, visual broadcasting of pornography or striptease clubs (the approach does not include literature, toys, DVD's, educational or scientific material or dating sites (e.g., Tinder))

• Personalised financial services related to holding high-net-worth individuals’ assets for them

• NGOs, political or religious organisations or individuals engaged directly or indirectly in offences against humanity and international security or offences against the state or offences against political and civil rights

Due to current geopolitical situation and aiming to mitigate the risk of financial sanctions evasion LHV does not initiate or continue business relationship with entities:

• Who are registered in Russia or Belarus

• Whose UBO is Russian or Belarus citizen and does not have a residence permit in the EEA or UK

Additionally, Banking Services customers are not allowed to establish customer relationships that are processed within LHV with private persons who are citizens of Russia or Belarus and do not have a residence permit in EEA or UK.

Deviation from the LHV risk appetite may result in the termination of the client agreement.