Back

Compliance with the sanctions applied in the EU/US/UK and the Republic of Estonia

LUMEROOS CAPITAL OÜ (LUMEROOS™) acknowledges and understands that specific individuals, organisations, companies, and other entities are subject to sanctions imposed by the European Union, United Nations, United States, United Kingdom and the Republic of Estonia following the International Sanctions Act (ISA). LUMEROOS, a financial market participant registered and performing its activities in the Republic of Estonia, is prohibited from engaging in transactions with (or transferring value to) such sanctioned entities and individuals.

LUMEROOS confirms that, as of the date of signing any agreement with other parties, neither LUMEROOS nor its owners, shareholders, officers, board members, employees, business ventures, or any of their family members are subject to the EU/US/UK/UN sanctions.

LUMEROOS further confirms that neither it nor any of its owners, shareholders, officers, board members, employees, business ventures, or their family members are connected to or engaged in business relationships with any sanctioned individuals, organisations, companies, or entities as defined in EU/US/UK/UN sanctions lists.

LUMEROOS confirms that neither it nor any of its business ventures, owners, shareholders, officers, board members, employees, or their family members are affiliated with any governmental subdivisions, agencies, instrumentalities, or government officials in a manner that would breach EU/US/UK/UN sanctions.

No portion of investment partners’ payments to LUMEROOS will be directed to or used to benefit any sanctioned individuals, organisations, companies, or entities as per EU/US/UK/UN sanctions lists.

Following the EU/US/UK foreign policy and sanctions, no portion of investment partners’ payments to LUMEROOS will be used in any manner that threatens any country’s peace, security, stability, or territorial integrity.

No portion of investment partners’ payments to LUMEROOS will be used to support, advance, or benefit actions or policies that violate or restrict any country’s human rights or fundamental freedoms.

Throughout the terms of any agreements with other parties, in such a context, LUMEROOS shall comply with the provisions of the International Sanctions Act (ISA) and the Money Laundering and Terrorist Financing Prevention Act (MLTFPA). LUMEROOS acknowledges that being subject to the EU/US/UK/UN sanctions may result in the immediate suspension or termination of any agreements to ensure compliance with UK/EU/US sanctions laws and any other termination provisions outlined in any agreements.