The Association of Latvian Commercial Banks (ALCB) underscores the need for a legal ban on cooperating with unacceptably high-risk clients, especially with shell companies that do not engage in real business activities. To manage the situation in an effective manner, a clear and unambiguous prohibition on cooperating with shell companies must be put into law. Other measures that would put a complete end to servicing high-risk non-resident clients in Latvian banks are under the responsibility of the Financial and Capital Market Commission.

According to our estimates, 90% of Latvian clients are serviced by four biggest banks in Latvia (Swedbank, SEB, Luminor, Citadele Bank), therefore the change in business model would affect only a fraction of the banking sector.

The ALCB expects that the institutions responsible for supervising the banking sector will act decisively to address the identified shortcomings and avoid any further negative reports from the US Treasury’s Financial Crimes Enforcement Network or from other international partners, statements which could completely destroy Latvia’s international reputation.
We believe that in order to continue working efficiently with the US and other international partners it is important to maintain regular and coordinated dialogue between all parties involved, thus ensuring coherent communication of the full range of the Latvian government’s planned actions.

In the event that the Moneyval report on Latvia, due to be published this autumn, proves to be unfavourable, we can confirm that it will bring immense challenges for banks servicing Latvian companies and residents. The Latvian government must do everything necessary to demonstrate clear action and commitment to fighting financial crime and to not allow Latvia’s banking system be used for unlawful activities which go against international practice and rights.

The ALCB will continue working on the consistent adoption of the Association’s self-regulation standards and their ever-stricter observance among ALCB members. It will also regularly re-evaluate the need for any additions to these documents, adding new requirements where needed.


Associate members