Official Statement of OJSC “Eldik Bank”
In connection with publications appearing in the mass media, OJSC “Eldik Bank” considers it necessary to provide an official clarification regarding the measures applied in the area of anti-money laundering and countering the financing of terrorism (AML/CFT), as well as sanctions risk management.
The Bank’s Position
OJSC “Eldik Bank” categorically does not permit its financial infrastructure to be used for circumventing international sanctions, money laundering, terrorist financing, or any other unlawful activity.
The Bank conducts its activities in strict compliance with the legislation of the Kyrgyz Republic and consistently improves its compliance control framework, taking into account applicable international AML/CFT standards and sanctions requirements of the United States, the European Union, and the United Kingdom.
The Bank applies enhanced control procedures to international and cross-border transactions, including sanctions screening of customers, counterparties, and transactions, verification of beneficial owners, analysis of the economic substance and purpose of payments, review of supporting documents, and, where applicable, verification of the source of funds. A key objective of this system is the timely identification and prevention of attempts to use the Bank’s financial infrastructure to circumvent international sanctions restrictions, launder money, or engage in other unlawful activities.
Clarifications Regarding A7 and OJSC “Trading Company of the Kyrgyz Republic”
In connection with references to A7 in publications, it is necessary to emphasize separately that the Bank has never had any contractual or other relationships with the company and has never opened bank accounts in the name of the company.
Media reports also refer to OJSC “Trading Company of the Kyrgyz Republic” (TC KR), which was previously a customer of the Bank. The relationship between Eldik Bank and TC KR was exclusively a standard bank-customer relationship. The Bank was not an affiliated entity of TC KR and had no other corporate or commercial ties with the company. Based on the documents and information provided to the Bank in connection with the relevant transactions, no connection between TC KR and A7 was established. At the same time, based on its risk-based approach, the Bank classified TC KR as a higher-risk customer and applied enhanced compliance procedures to the company. During the course of monitoring, all transactions were classified by the Bank as suspicious. In accordance with established procedures, the relevant information was submitted to the competent state authority. Subsequently, Eldik Bank unilaterally terminated its business relationship with TC KR and closed the company’s accounts.
OJSC “Eldik Bank” attaches particular importance to the independent external assessment of the effectiveness of its AML/CFT and sanctions risk management framework. In 2026, the Bank engaged an international audit firm from the Big Four to conduct an independent review of the completeness, accuracy, and adequacy of the measures applied by the Bank in the area of AML and compliance with international sanctions requirements. Following the review, it was noted that the Bank takes sufficient measures within the applicable requirements and control procedures.
In addition, the Bank engaged the international law firm Dentons to conduct an independent legal assessment of sanctions risks from the perspective of the legislation and sanctions regimes of the United States, the European Union, and the United Kingdom. Dentons specialists in Brussels and London prepared a relevant legal opinion on sanctions-related matters (Sanctions Opinion).
As part of its ongoing efforts to further strengthen its compliance control framework, the Bank also initiated a separate independent external assessment of its sanctions risk management and financial crime risk management systems. For this purpose, OJSC “Eldik Bank” engaged an international company specializing in risk management, financial investigations, and compliance consulting.
As part of the independent assessment, the Bank’s sanctions compliance framework is being reviewed against 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 implementation, including customer and beneficial ownership identification mechanisms, sanctions screening, transaction monitoring, enhanced due diligence procedures for higher-risk customers, escalation mechanisms, and internal controls. The work is already underway. The final report on the results of the independent assessment is expected shortly. The recommendations developed following the assessment will be used by the Bank to further improve its sanctions and compliance risk management framework.
Strengthening the Sanctions Risk Management Framework
OJSC “Eldik Bank” has a dedicated Sanctions Risk Management Committee, which provides an additional level of oversight and coordination of measures aimed at managing sanctions risks.
As part of the consistent strengthening of these efforts, during the current year alone, OJSC “Eldik Bank” unilaterally terminated business relationships with and closed the accounts of more than 120 companies on grounds related to identified compliance risks.
The Bank remains open to professional and constructive engagement with regulatory authorities, international partners, correspondent banks, and the mass media and is prepared to provide the necessary clarifications to the extent permitted by applicable law and banking secrecy requirements.
Ensuring transparency in international transactions, protecting the Bank’s financial infrastructure, and maintaining the trust of customers, partners, correspondent banks, and international financial institutions remain unconditional priorities for OJSC “Eldik Bank.”
