"A 2008 systematic review, published in BMJ, found medical masks halted the spread of respiratory viruses from likely infected patients. In particular, studies on the 2003 outbreak of SARS — a cousin to the coronavirus that causes Covid-19 — found that masks alone were 68 percent effective at preventing the virus. By comparison, washing hands more than 10 times a day was 55 percent effective. A combination of measures — hand-washing, masks, gloves, and gowns — was 91 percent effective."
"Swedbank Estonia and Swedbank Latvia actively pursued these high risk customers as a business strategy.
[..] Swedbank Latvia customers used an online banking platform to initiate 522 outgoing Subject Transactions, totaling approximately $4.43 million, of which 507 such outgoing Subject Transactions between 30 December 2014 and 30 December 2016, amounting to approximately $4.26 million, involved three shipping customers domiciled in offshore jurisdictions that had accounts at Swedbank Latvia but whose owner appeared to operate these companies from Crimea. The remaining 15 outgoing Subject Transactions from accounts at Swedbank Latvia appeared to involve non-sanctioned customers who were temporarily located in Crimea or Iran or payments by non-sanctioned customers to counterparties in Crimea. We also identified one incoming Subject Transaction for $5,970 to an individual customer of Swedbank Latvia who had a residency address in Crimea.
Apparent OFAC-Sanctioned Customers of Swedbank Latvia:
One non-SDN company wholly-owned by an SDN under the Russia/Ukraine-related sanctions
Five individuals who appeared to reside in Crimea during a relevant time period
One individual who appeared to reside in Iran during a relevant time period
Two individuals who appeared to reside in Syria during a relevant time period
This report further explained that the majority of the beneficial owners for the corporate non-resident customers in Estonia and Latvia were of Russian and Commonwealth of Independent States (“CIS”) origin; these Russian and CIS customers favored Hansabank since the 1990s “[d]ue to geographical proximity, political situation and volatile economic situation in Russia[,] and high standards of banking services in [the] Baltics. According to this report, these Russian and CIS companies associated with a proxy network, and payments between 2010 and 2013 to offshore companies allegedly linked to payments to associates of a former Ukrainian President.
A manager within Swedbank Latvia’s GSI unit reported that Swedbank Latvia maintained relationships with these customers despite inadequate KYC information. Swedbank Latvia also attributed the growth of its HRNR business to a Latvian “residence permit program” that, until 2016, gave foreigners temporary residency permits if they invested in Latvian real estate.
Contemporaneous exchanges between an AML officer and employees from Swedbank Latvia’s Non-Resident Banking Unit—at that time, a unit comprised of about ten full-time employees (including RMs) housed within Private Banking—reflect an effort to build a “short list” of existing customers to present for authorization under the Decree’s exception provision. The latest identified version of the “short list,” dated 25 September 2007, identified 36 customers for review. The Investigation has identified that of these 36 customers, five were closed in 2007, an additional three were closed in 2008 and Swedbank Latvia continued its relationships with the remaining 28 customers until their accounts were closed by the end of 2016.( ... tālāk ... )
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