Official Statement of OJSC “Eldik Bank”
In response to recent media reports, Eldik Bank OJSC wishes to provide an official clarification regarding its Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) measures, as well as its sanctions risk management compliance.
The Bank’s Position
Eldik Bank OJSC strictly prohibits the use of its financial infrastructure to circumvent international sanctions, launder money, finance terrorism, or engage in any other illicit activities.
The Bank operates in strict compliance with the laws of the Kyrgyz Republic and consistently enhances its compliance control framework, aligning it with applicable international AML/CFT standards and the sanctions regulations of the United States, the European Union, and the United Kingdom.
The Bank applies enhanced due diligence (EDD) procedures to international and cross-border transactions. These measures include sanctions screening of clients, counterparties, and transactions, ultimate beneficial owner (UBO) verification, and the analysis of the economic substance and purpose of payments. Additionally, the Bank reviews supporting documentation and, where applicable, verifies the source of funds. The primary objective of this system is to timely detect and prevent any attempts to utilize the Bank’s infrastructure to circumvent international sanctions, launder money, or engage in other illicit activities.
Clarification Regarding A7 and Trading Company of the Kyrgyz Republic OJSC
Regarding the mention of A7 in recent media reports, the Bank emphasizes that it has never maintained any contractual or other business relationships with this entity, nor has it ever opened any bank accounts for it.
Media reports also reference Trading Company of the Kyrgyz Republic OJSC (TC KR), a former client of the Bank. The relationship between Eldik Bank and TC KR was strictly limited to a standard bank-client relationship. The Bank was not an affiliate of TC KR and maintained no other corporate or commercial ties with the company. Based on the documentation and information provided to the Bank during the relevant transactions, no connection was established between TC KR and A7.
At the same time, based on a risk-based approach, the Bank classified TC KR as a high-risk client and applied enhanced due diligence (EDD) procedures to the company. Through ongoing monitoring, all operations were flagged by the Bank as suspicious. In accordance with established protocols, the relevant information was forwarded to the authorized state agency. Subsequently, Eldik Bank unilaterally terminated its business relationship with TC KR and closed the company's accounts.
Eldik Bank OJSC attaches particular importance to the independent external evaluation of its AML/CFT framework and sanctions risk management system. In 2026, the Bank engaged a Big Four international auditing firm to conduct an independent review of the completeness, accuracy, and adequacy of the Bank's AML measures and its compliance with international sanctions regulations. The review concluded that the Bank takes adequate measures within the scope of the relevant compliance requirements and control procedures.
Additionally, to obtain an independent legal assessment of its sanctions risks under the laws and sanctions regimes of the United States, the European Union, and the United Kingdom, the Bank retained the international law firm Dentons. Dentons' experts in Brussels and London subsequently issued a comprehensive Sanctions Opinion on these matters.
To further strengthen its compliance control framework, the Bank has also initiated a separate independent external assessment of its sanctions and financial crime risk management systems. To conduct this work, Eldik Bank OJSC has engaged a leading international firm specializing in risk management, financial investigations, and compliance consulting.
This independent review evaluates the Bank’s sanctions compliance system against the applicable requirements and standards of the United Kingdom, the United States, and the European Union. The assessment covers both internal policies and procedures and the effectiveness of their practical application. This includes client and beneficial owner identification mechanisms, sanctions screening, transaction monitoring, enhanced due diligence (EDD) procedures for high-risk clients, and escalation and internal control protocols. The review is already underway, with the final report expected in the near future. The recommendations resulting from this assessment will be used by the Bank to further enhance its sanctions and compliance risk management framework.
Strengthening the Sanctions Risk Management System
Eldik Bank OJSC operates a specialized Sanctions Risk Management Committee, which provides an additional layer of oversight and coordinates compliance measures.
As part of its ongoing efforts to strengthen these controls, during the current year alone, Eldik Bank OJSC has unilaterally terminated business relationships and closed the accounts of more than 120 companies due to identified compliance risks.
The Bank remains open to professional and constructive engagement with regulatory authorities, international partners, correspondent banks, and the media, and stands ready to provide necessary clarifications within the boundaries permitted by law and bank secrecy regulations.
Ensuring the transparency of international operations, protecting the Bank’s financial infrastructure, and maintaining the trust of clients, partners, correspondent banks, and international financial institutions remain the absolute priorities of Eldik Bank OJSC.
