Frequently Asked Questions

If the electronic money institution is not provided with the necessary information or requested documents, in some cases the electronic money institution will no longer be able to provide you with services, e.g. it may refuse or suspend the execution of monetary operations or transactions, or apply restrictions on the use of the account. Please note that the money in your electronic wallet will not disappear, but you will be able to use the electronic money institution’s services only after you provide the necessary information or documents. In addition, if the electronic money institution does not receive the required information (or requested documents) from you, it may terminate its business relationship with you.

The section indicating the purpose of the payment is required not only to provide the payee with the information on the payment, but also to explain to the electronic money institution (as a service provider) the real purpose of this monetary transaction. We expect proper business communication from our Customers, therefore, we advise you to avoid ambiguities when specifying the purpose of payment, and to specify the purpose of payment precisely.

The law obliges us to receive the information specified in the Questionnaire directly from our Customers. The information available to these authorities can be used as an additional source of data to verify the information you provide.

Certain Accounts and Services (referred to collectively as Products) are prohibited from being offered by FUNDSTR UAB to its customers. These products are prohibited because they are outside of the institution´s risk appetite:

• Countries, governments, entities and individuals subject to sanctions or included in any applicable internal lists
• Anonymous or numbered accounts of Customers seeking to maintain an account in an obviously fictitious name
• Customers whose identities are not known or cannot be verified
• Shell banks (an entity that has no physical existence in the country in which it is incorporated and licensed, and which is unaffiliated with a regulated financial group that is subject to effective consolidated supervision)
• Unlicensed or unregistered financial institutions, for example, broker-dealers in jurisdictions, which require license and/or registration
• Unlicensed or unregistered Money Services Businesses (MSBs) irrespective of whether the jurisdiction requires a licence and/or registration or not
• Any individual or entity prohibited by law by holding an account outside their home jurisdictions (e.g. foreign politically exposed persons).
• A Customer who is resident, incorporated or registered in a high risk jurisdiction and operates in any of the following industries: money service businesses, gambling/gaming, defence or military, extractive industries, healthcare/pharmaceutical or construction
• Payable-through accounts through domestic or foreign bank customers
• Hold Mail: where the customer has instructed the EMI to hold all documentation related to the account on their behalf until collection
• Remittance Services for Non-Customers
• Travellers cheques and U.S. Postal Money Orders
• The physical transportation of currency and monetary instruments by employees, i.e. bulk cash on behalf of customers
• Get rich quick schemes, Ponzi schemes, snow ball schemes, investment clubs or similar activities
• Astrological services, paranormal services, counselling, psychological services, on-line health assessment, star naming services
• Fake or counterfeit goods, novelty IDs
• Dangerous or restricted goods (including but not limited to explosives, radioactive materials, toxic substances, batteries, fireworks, weapons, knives and ammunition
• Protected works of art, history and culture
• any other goods or services whose sale, provision, delivery, offering or marketing is prohibited or restricted in the jurisdiction of the Merchant or in any jurisdiction where any of its customers is located
• Virtual Currency / Cryptocurrency, for example a medium of exchange that operates like a currency in some environments but is not issued by a Central Bank or Public Authority nor has a legal tender status in any jurisdiction

FUNDSTR maintains strict ethical and moral standards in its work and it collaborates with Customers whose funds and assets are legitimate, with no doubts about its legality. Customer’s activities must be explained in the appropriate Customer Questionnaire for Natural Persons or Legal Entities, as required. It is also important that all Customer’s transactions done using our infrastructure match the Customer’s activities and/or their usual behaviour and the information that the Customer has supplied to the electronic money institution initially. A transparent source of funds means that the Customer has documents showing the legality of the funds acquired by Customer or a legal entity that Customer controls, and if required these documents can be provided for the electronic money institution. We encourage our Customers to choose their business partners carefully, as through these partners our Customers may be unknowingly implicated in money laundering schemes or in maintaining business relations with sanctioned entities. As a result, Customers can risk their own reputation.
The electronic money institution must ensure that the money laundering and terrorist financing risk assessment is based on up-to-date and accurate information, and it must therefore regularly review and update the documents, data and information provided during the identification of the Customer and the beneficiary. The Customer must notify the electronic money institution about any changes in this data.

Electronic money institutions are bound by very strict legal requirements to implement the “Know Your Customer” principle and to reduce the various risks associated with illegal activities. Electronic money institutions must ensure that their infrastructure is not used by individuals who pose a threat to others and must therefore ensure that the origin of the Customer’s assets and funds is transparent, that monetary transactions are understandable, economically sound and in line with declared activities.
The frequency of the update depends on various circumstances, e.g. potential risks of money laundering and terrorist financing. The electronic money institution will inform you of the upcoming date by which the Questionnaire must be updated.

If the electronic money institution is not provided with the necessary information or requested documents, in some cases the electronic money institution will no longer be able to provide you with services, e.g. it may refuse or suspend the execution of monetary operations or transactions, or apply restrictions on the use of the account. Please note that the money in your electronic wallet will not disappear, but you will be able to use the electronic money institution’s services only after you provide the necessary information or documents. In addition, if the electronic money institution does not receive the required information (or requested documents) from you, it may terminate its business relationship with you.

The section indicating the purpose of the payment is required not only to provide the payee with the information on the payment, but also to explain to the electronic money institution (as a service provider) the real purpose of this monetary transaction. We expect proper business communication from our Customers, therefore, we advise you to avoid ambiguities when specifying the purpose of payment, and to specify the purpose of payment precisely.

The law obliges us to receive the information specified in the Questionnaire directly from our Customers. The information available to these authorities can be used as an additional source of data to verify the information you provide.

We ask our clients or their representatives to provide information about the fact that they or their family members (spouse, co-habiting partner, parents, siblings, children and children’s spouses, children’s co-habiting partners), close associates (persons with whom a person has common business, keeps professional or business relationship) presently occupy or in the recent 12 months have held an important public position in any state and/or international institution since the electronic money institution has to conduct enhanced monitoring of business relationship / monetary transactions of such clients.

Important public position shall be considered the following:

• Head of the State, Head of the Government, a minister, a vice minister or a deputy minister, State Secretary, the Chancellor of the Parliament, Government or Ministry
• Member of the Parliament
• Member on the Supreme Court, the Constitutional Court or any other judicial authority, whose decisions are not subject to further appeal
• Mayor of the municipality, director of the municipal administration
• Member of the management body of the national supreme audit and control institution, the chairperson, deputy chairperson or a member of the board of the central electronic money institution
• Ambassador, chargés d’affaire, Chief of Defence of the Republic of Lithuania, commanders of the armed forces and units, Chief of the Defence Staff or high-ranking officer in the armed forces of foreign country
• Member of the management or supervisory body of a state enterprise, public company, private company all or part of shares of which awarding more than ½ of all votes in the general meeting of shareholders of these companies are held by the State by right of ownership
• Member of the management or supervisory body of a municipal enterprise, public company, private company all or part of shares of which awarding more than ½ of all votes in the general meeting of shareholders of these companies are held by the State by right of ownership and which are considered to be large enterprises within the meaning of the Law of the Republic of Lithuania on Financial Reporting by Undertakings
• Head, deputy head, member of the administrative, management or supervisory body of international intergovernmental organization
• Leader, deputy leader, member of the administrative, management body of the political party

Please note that if you are a family member or immediate helper of a politically exposed person, you must supply the required information about this politically exposed person.

Ordering an IBAN is an easy process which requires just a few steps: (1) In the homepage of your profile, in the Wallets section, there is a menu " …", please click on it. (2) Once you click on the menu, a dropdown menu will appear. (3) From the dropdown, you should select Products ordering. (4) The last step would be for you to click the Order button and then click Next. Once the IBAN is successfully created, you will see a message in green that the operation was successful.

International Sanctions are restrictive non-military measures put in place in order to preserve the international peace and security, as well as respect for human rights.
They are imposed by the United Nations (UN), the European Union (EU) or by individual countries (e.g. the United States (U.S.)). International Sanctions are imposed against entire states, as well as natural persons and legal entities, who violate the human rights, commit religious, ethnical, territorial conflicts, support terrorism, violate other international norms and principles.
The purpose of International Sanctions is to influence a change of behaviour, to stop prohibited activities or to restrain the sanctioned person. International Sanctions take various forms based on their purpose objective (e.g. to prevent armed conflict, counter terrorism). They can be individual (e.g. travel ban, asset freeze), target goods and services (e.g. arms embargoes or proliferation-related goods, dual-use goods), can be focused on core economic sectors (e.g. oil or financial sectors) or be comprehensive targeting entire country (e.g. North Korea).
FUNDSTR, as well as other financial institutions, implements International Financial Sanctions.
FUNDSTR implements above mentioned International Sanctions to the extent determined by the UN, the EU, the U.S. or state bodies (i.e. Government) and according to the FUNDSTR Sanctions Policy as well as its own risk appetite. Therefore, FUNDSTR will not engage in any actions that directly or indirectly evade the Financial Sanctions prohibitions and FUNDSTR’s internal decisions.

EU imposed International Sanctions (including implemented UN sanctions) apply within the territory of EU and to all EU persons inside or outside the territory of EU. Thus, both financial institutions and their Customers are legally responsible for complying with the EU sanctions and have the obligation to inform the competent authorities on the cases they know or suspect transactions with sanctioned subjects. FUNDSTR will always inform the competent authorities in case of breach of the EU Sanctions and freezing of funds. Examples when reporting is necessary:

• The Customer identifies that its partner or Customer is the EU sanctioned person
• The Customer identifies that beneficial owner of the legal entity which buys goods/services is the EU sanctioned person

Due to International Sanctions, FUNDSTR has the right not to execute transactions in any currencies related to the EU and U.S. comprehensively sanctioned countries/regions:

• Iran
• Syria
• North Korea
• Crimea, Sevastopol
• Cuba

FUNDSTR may also hold the Customer’s transaction to/from any country/region where embargoes, other restrictive measures are imposed or to/from other high-risk countries/regions in order to investigate whether this transaction is not related to International Sanctions and is in line with electronic money institutions’ requirements, as well as with FUNDSTR’s internal decisions and its own risk appetite. The execution of stopped international transactions may be delayed and Customers may be asked to provide additional information and/or documents about their transactions because of such investigation.
In assessing if transaction is related to the sanctioned countries/regions FUNDSTR will investigate connections to imposed International Sanctions and analyse additionally:

• If transaction is related to a counterparty located or operating in one of the above-mentioned countries/regions. The relation could be direct (e.g. transaction is received from the sender with the address in Crimea) or indirect (e.g. transaction is received from other country (e.g. Turkey) but goods are being sent to Syria)
• If transaction is related to front companies which help to avoid direct connection to the above-mentioned countries/regions
• If information provided in transaction details could be linked to the above-mentioned countries/regions (e.g. person name, vessel, name of city, harbour etc.)
• If transaction lacks a substantial information to understand the transaction’s purpose

(1) In the homepage of your account, in the Transactions section, you can see all the transactions that you have created (2) Find the transaction that you are referring to, and click on the transaction number (you can see it in the Txn ID field) (3) Once you open it, in the right corner of the page there are two options: Print Confirmation and Search for Similar (4) Click on Print Confirmation and you will get a printable .pdf confirmation of your payment

We collect and use your personal data, which you provide yourself, and which we obtain from other external sources, such as public or private registries or other third parties. We process your personal data for the following main purposes:

• In order to identify you and authenticate your identity and to contact you, we collect your name, surname, personal identification number, date of birth, copy of your identity document, address, telephone number and other contact details.
• In order to implement the requirements for the prevention of money laundering and terrorist financing and to determine whether we can establish / continue a business relationship with you, as well as to ensure that all requirements related to the application of sanctions are met, we collect / update the data relating to your job, current position, citizenship, data on whether you are a politically exposed person as well as other data necessary to ensure the implementation of the "Know Your Customer" principle.
• In order to provide you with services and to properly fulfil our contractual obligations, as well as to fulfil our duties prescribed by law, we process the personal data provided by you (e.g. name, surname, telephone number, account number) and other information to the extent necessary for the provision of such services and for the fulfillment of obligations.
• In order to provide payment services related to Application Programming Interface (API), we collect and use, in accordance with legal requirements and with your consent, data such as your account number with another account manager, currency, name, type, balance of account, and in the case of account information service, also a list of payment transactions in the selected accounts and details of the transactions, including reserved amounts, information on whether the account has a credit limit, etc. By providing these services, we may transfer your IP address, browser and its version information in relation to the devices you use to other payment service providers that manage your accounts.
• To identify you in compliance with regulatory requirements, where you are identified without your physical presence, we make video recordings and/or take photos and process your image/portrait data.
• In order to prevent violations of legal acts as well as to protect you and your property from criminal acts (e.g. by misappropriating your data, identity), we collect and systematize information about possible misuse of FUNDSTR UAB services. For this purpose, we may also use contact information and security data of payment instruments as well as payment transaction data to protect transactions and communications on our remote networks.

We obtain and use your personal data under at least one of the following conditions:

• You intend to conclude or have concluded an agreement with FUNDSTR UAB
• You have given your consent - when we send you direct marketing messages
• Processing of personal data is mandatory on the basis of legal acts - as provided by legal acts regulating the activities of financial market players and the services they provide
• The processing of your data is necessary for the performance of a task carried out in the public interest when we implement measures for the prevention of money laundering and terrorist financing

For the purpose of our legitimate interests, such as:

• to improve the quality of our offerings, to ensure the consistency and sustainability of our activities, the comprehensiveness of the services provided to you and their conformance with your expectations as well as your maximum satisfaction with our services
• to bring and defend legal actions and take other lawful actions to prevent or reduce losses
• to systematically monitor and prevent illegal acts and regularly assess the risks associated with them (e.g. unauthorized use of payment cards or other payment instruments, etc. that we have issued to you).

We collect your basic personal data, such as, but not limited to:

• Basic personal data, such as name, surname, personal identification number, date of birth, telephone number, e-mail, postal address, residential address or address for correspondence
• Identification data, such as personal document data, photo, IP address, website login details and other browsing information, including details of when and from where you accessed our electronic payments platform and website
• Data on your transactions in FUNDSTR UAB and other concluded agreements, depending on the services provided to you by FUNDSTR UAB, e.g. account number, deposits, payment orders and / or other payment transactions, payment instruments and actions performed using them, monetary deposits, withdrawals, etc.
• Financial data, such as the origin of funds, country of residence for tax purposes, accounts, payment documents, financial liabilities, assets, their types and value
• Data obtained to meet regulatory requirements, such as data obtained from inquiries of law enforcement authorities, etc
• Legal representatives (acting on a power of attorney or on any other basis)
• Payers and payees
• Counterparties and participants
• Ultimate beneficial owners (UBO)

We provide your personal data in accordance with legal requirements. Your personal data may be transferred to:

• Other banks and financial institutions
• Payment and other service providers involved in the execution of your transaction with us (for example, to execute a payment, personalize a payment card, etc.)
• Bank of Lithuania
• State Tax Inspectorate with the aim to comply with tax laws, the Agreement between the Government of the Republic of Lithuania and the Government of the United States of America on the Improvement of Cross-Border Tax Compliance and on the Implementation of the Foreign Account Tax Compliance Act and other international commitments of the Republic of Lithuania in this area
• Financial Crime Investigation Service, courts and other law enforcement authorities at their request or on our own initiative, if there is suspicion that criminal offense has been committed
• Our professional advisors, auditors
• Courts, arbitrators or other dispute resolution or law enforcement authorities, where they have the right to obtain such information in accordance with the procedure established by law
• Other third parties as regards our sale of business, mergers, acquisitions or reorganization of our business, in whole or in part, or in connection with similar change in business (including, among other things, potential or existing business buyers and their advisers).
• Also, to process personal data, we use the following data processors, including without limitation: companies providing data centre, hosting, cloud, site administration and related services; document archiving companies; advertising, marketing companies; software design, supply, support and development companies; companies offering information technology infrastructure services; companies delivering communication services; companies rendering advisory services; companies analysing the Internet browsing or Internet activity

We process and store your personal data within the European Union, however, we may transfer your personal data outside the EU / EEA, for example, when necessary for the conclusion and performance of a contract or if you have consented to such transfer.
Payment and other service providers involved in the execution of your transaction with us may be located or operating in a country that does not provide an adequate level of data protection (i.e. in a country that is not a party to the Agreement of the European Economic Area and is not included by the European Commission into the list of countries with an adequate level of data protection). We employ every means to ensure secure use of your personal data, however, there may be cases where we will not be able to ensure the recipient’s compliance with the same requirements as in the European Union.

We store your personal data for no longer than is necessary for the purposes, for which they were collected or for the period required by law, i.e.:

• The data collected in connection with the provision of services, including video data collected during a remote access advisory meeting or when identifying the person by remote access, we process for as long as you use our services, and retain for a further 10 years after you cease using our services
• Data of persons related to legal entities, i.e. managers, representatives, shareholders, etc.), where such person does not have any personal agreements with FUNDSTR UAB, for a further 10 years since the end of business relationship with the legal entity
• Data of potential customers (for whom an offer was provided, but no contract was concluded) are stored for 2 years from the date of the decision not to conclude a contract - taking into account the 2-year limitation period for filing a complaint to the State Data Protection Inspectorate
• Data of a consent for marketing purposes - 3 years from the date of the consent
• We process the personal data you have submitted on social networks Facebook, Youtube, Linkedin, Instagram until the moment of revocation of your consent (i.e. deletion of the submitted data from the account), but not longer than until the deletion of the FUNDSTR UAB account. We note that personal data are processed only on the social network manager’s platform, therefore, the exact terms and conditions for processing are determined by the platform manager

We employ a variety of security technologies and procedures to protect your personal information from unauthorized access, use or disclosure. Our suppliers are carefully selected, and we require them to use appropriate measures to protect your confidentiality and ensure your personal information security. However, the security of information transmission by e-mail or mobile communication may sometimes be uncertain for reasons beyond the control of FUNDSTR UAB, therefore, you should be careful when providing us with confidential information via electronic systems other than those used by FUNDSTR UAB

Certain Accounts and Services (referred to collectively as Products) are prohibited from being offered by FUNDSTR UAB to its customers. These products are prohibited because they are outside of the institution´s risk appetite:

• Countries, governments, entities and individuals subject to sanctions or included in any applicable internal lists
• Anonymous or numbered accounts of Customers seeking to maintain an account in an obviously fictitious name
• Customers whose identities are not known or cannot be verified
• Shell banks (an entity that has no physical existence in the country in which it is incorporated and licensed, and which is unaffiliated with a regulated financial group that is subject to effective consolidated supervision)
• Unlicensed or unregistered financial institutions, for example, broker-dealers in jurisdictions, which require license and/or registration
• Unlicensed or unregistered Money Services Businesses (MSBs) irrespective of whether the jurisdiction requires a licence and/or registration or not
• Any individual or entity prohibited by law by holding an account outside their home jurisdictions (e.g. foreign politically exposed persons).
• A Customer who is resident, incorporated or registered in a high risk jurisdiction and operates in any of the following industries: money service businesses, gambling/gaming, defence or military, extractive industries, healthcare/pharmaceutical or construction
• Payable-through accounts through domestic or foreign bank customers
• Hold Mail: where the customer has instructed the EMI to hold all documentation related to the account on their behalf until collection
• Remittance Services for Non-Customers
• Travellers cheques and U.S. Postal Money Orders
• The physical transportation of currency and monetary instruments by employees, i.e. bulk cash on behalf of customers
• Get rich quick schemes, Ponzi schemes, snow ball schemes, investment clubs or similar activities
• Astrological services, paranormal services, counselling, psychological services, on-line health assessment, star naming services
• Fake or counterfeit goods, novelty IDs
• Dangerous or restricted goods (including but not limited to explosives, radioactive materials, toxic substances, batteries, fireworks, weapons, knives and ammunition
• Protected works of art, history and culture
• any other goods or services whose sale, provision, delivery, offering or marketing is prohibited or restricted in the jurisdiction of the Merchant or in any jurisdiction where any of its customers is located
• Virtual Currency / Cryptocurrency, for example a medium of exchange that operates like a currency in some environments but is not issued by a Central Bank or Public Authority nor has a legal tender status in any jurisdiction