Compliance

Parties related to the bank are deemed to be controllers, qualifying holders, members of the bank’s management and control bodies, as well as legal entities or individuals that have close economic, corporate, or managerial ties with the bank or with persons who exert influence over its activities. Such persons include shareholders who directly or indirectly hold a qualifying interest, executives, members of supervisory and executive bodies, internal audit units, risk management and compliance functions, as well as organizations in which these persons exercise control or hold managerial positions.

A qualifying interest is defined as ownership of ten percent or more of the share capital or voting rights, or the ability to exercise decisive influence over the institution’s management through formal or informal arrangements.

A controller is a person who has a decisive influence over the bank’s activities, including those who hold a significant share of capital or are able to control managerial decision-making.

The bank informs an individual of their status by sending an official notification. Such notification does not require a response and is purely informational in nature, as the recognition of relatedness is based on factual circumstances and statutory requirements. At the same time, granting this status does not limit the individual’s ability to obtain banking services. Persons related to the bank may open accounts, place deposits, obtain loans, and use other financial products of the bank. All such transactions are carried out strictly on standard, market-based terms that correspond to those applicable to other clients of the bank with a similar financial profile. This means that the bank is prohibited from offering preferential interest rates, reduced collateral requirements, or other special conditions that may indicate advantages compared to other clients. Any agreements concluded on non-market or preferential terms are deemed invalid from the moment of execution.

During martial law, certain transactions for related parties are subject to additional restrictions. In particular, early withdrawal of term deposits by such persons is prohibited, except where the funds are used to increase the bank’s capital. This restriction is introduced to ensure the stability of the banking system during a special period and to prevent liquidity outflows.

The status of a related person also affects deposit guarantee coverage. In the event the bank is declared insolvent, funds of related parties are not subject to reimbursement within the guaranteed amount, unlike the funds of other depositors. The procedure and scope of any potential recovery of such funds are determined by separate regulatory acts and apply only after completion of the established resolution procedure.