{"kind":"evidence_file","company":{"id":"72688ce3-858a-42c6-af99-07050d42629b","name":"Renesource Capital","mergedInto":null},"asOf":"2026-10-24T18:38:03.065Z","asOfBasis":"instant","generatedAt":"2026-10-27T16:23:30.172Z","claims":[{"predicate":"name","value":"renesource capital","source":"ESMA Sanctions Register","sourceUrl":"https://registers.esma.europa.eu/publication/searchRegister?core=esma_registers_sanctions","sourceRecordId":"sn10655","observedAt":"2026-09-12T19:04:54.764Z","confirmedAt":"2026-10-16T12:00:05.910Z","validFrom":null,"validTo":null,"supersededLater":null},{"predicate":"primary_country","value":"LV","source":"ESMA Sanctions Register","sourceUrl":"https://registers.esma.europa.eu/publication/searchRegister?core=esma_registers_sanctions","sourceRecordId":"sn10655","observedAt":"2026-09-12T19:04:54.768Z","confirmedAt":"2026-10-16T12:00:05.913Z","validFrom":null,"validTo":null,"supersededLater":null}],"listings":[{"listingId":"10655","regime":"Latvijas Banka","program":"Debarment","state":"lifted","stateSince":"2026-09-12T19:14:37.309Z","recordedAt":"2026-09-12T19:04:54.785Z","designatedAt":"2020-06-09T00:00:00.000Z","validTo":null,"legalBasis":null,"reason":"The Financial and Capital Market Commission (FCMC) and investment firm AS \"Renesource Capital\" (Renesource Capital) have entered into an administrative agreement, agreeing on the necessary improvements to the activities of the investment firm in order to address the shortcomings identified during inspections carried out by the FCMC. The agreement stipulates a fine of EUR 34 000 for infringements of the Financial Instruments Market Law (FIML) on Renesource Capital as well as a fine of EUR 34 000 for infringements of the Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing (AML law). A fine of EUR 2900 is also applied to the Chairman of the Board Mārtiņš Priede. During the inspections, the FCMC identified a number of violations of regulatory requirements in the activities of Renesource Capital, such as applying covert commissions, providing incomplete and untimely information on expenses and costs before and after a transaction, failure to timely notify a customer of planned costs and expenses before the provision of investment services or ancillary services, as well as shortcomings in internal governance. In addition, an effective AML/CTPF internal control system, specific to the nature of Renesource Capital’s activities and to risks inherent in the services provided was not ensured, resulting in breaches of the AML/CTPF regulatory framework in particular with regard to customer due diligence and transaction monitoring. As part of inspection, the FCMC concluded that Mārtiņš Priede, Chairman of the Board of Renesource Capital, as the responsible person for monitoring the AML/CTPF field, did not ensure that Renesource Capital took appropriate measures to guarantee effective functioning of AML/CTPF internal control system and independence of risk management functions, thereby exposing Renesource Capital to the money laundering and reputational risks. When deciding on the administrative agreement and determining the amount of fine applicable, the FCMC took into account the fact that Renesource Capital had cooperated with the FCMC, including voluntarily eliminated most of identified infringements and started work to address the remaining deficiencies. In order to avoid irregularities identified during the inspections, the administrative agreement includes the following measures which Renesource Capital undertakes to fully comply with in the time limits specified. Renesource Capital should provide an adequate and sufficient compliance monitoring and risk control system in line with the specific nature of the activities of Renesource Capital by the deadline specified by the FCMC, as well as take the necessary measures for enhancing the internal control system in the field of AML/CTPF and sanctions risk management under the requirements of the Financial Instruments Market Law.","sanctionType":null,"documentUrl":"https://registers.esma.europa.eu/publication/details?core=esma_registers_sanctions&docId=sn10655","assertedBy":["ESMA Sanctions Register"],"sourceNow":"ESMA Sanctions Register"},{"listingId":"10655","regime":"Latvijas Banka","program":"MiFID","state":"lifted","stateSince":"2026-10-23T12:00:21.167Z","recordedAt":"2026-09-12T19:14:22.947Z","designatedAt":"2020-06-09T00:00:00.000Z","validTo":null,"legalBasis":null,"reason":"The Financial and Capital Market Commission (FCMC) and investment firm AS \"Renesource Capital\" (Renesource Capital) have entered into an administrative agreement, agreeing on the necessary improvements to the activities of the investment firm in order to address the shortcomings identified during inspections carried out by the FCMC. The agreement stipulates a fine of EUR 34 000 for infringements of the Financial Instruments Market Law (FIML) on Renesource Capital as well as a fine of EUR 34 000 for infringements of the Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing (AML law). A fine of EUR 2900 is also applied to the Chairman of the Board Mārtiņš Priede. During the inspections, the FCMC identified a number of violations of regulatory requirements in the activities of Renesource Capital, such as applying covert commissions, providing incomplete and untimely information on expenses and costs before and after a transaction, failure to timely notify a customer of planned costs and expenses before the provision of investment services or ancillary services, as well as shortcomings in internal governance. In addition, an effective AML/CTPF internal control system, specific to the nature of Renesource Capital’s activities and to risks inherent in the services provided was not ensured, resulting in breaches of the AML/CTPF regulatory framework in particular with regard to customer due diligence and transaction monitoring. As part of inspection, the FCMC concluded that Mārtiņš Priede, Chairman of the Board of Renesource Capital, as the responsible person for monitoring the AML/CTPF field, did not ensure that Renesource Capital took appropriate measures to guarantee effective functioning of AML/CTPF internal control system and independence of risk management functions, thereby exposing Renesource Capital to the money laundering and reputational risks. When deciding on the administrative agreement and determining the amount of fine applicable, the FCMC took into account the fact that Renesource Capital had cooperated with the FCMC, including voluntarily eliminated most of identified infringements and started work to address the remaining deficiencies. In order to avoid irregularities identified during the inspections, the administrative agreement includes the following measures which Renesource Capital undertakes to fully comply with in the time limits specified. Renesource Capital should provide an adequate and sufficient compliance monitoring and risk control system in line with the specific nature of the activities of Renesource Capital by the deadline specified by the FCMC, as well as take the necessary measures for enhancing the internal control system in the field of AML/CTPF and sanctions risk management under the requirements of the Financial Instruments Market Law.","sanctionType":null,"documentUrl":"https://registers.esma.europa.eu/publication/details?core=esma_registers_sanctions&docId=sn10655","assertedBy":["ESMA Sanctions Register"],"sourceNow":"ESMA Sanctions Register"}],"ownership":[],"lists":[{"source":"Australia DFAT Consolidated List","readAt":"2026-10-19T06:31:20.009Z","recordsRead":3650,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 19 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Brazil CEIS (national procurement exclusions)","readAt":"2026-10-21T07:09:26.477Z","recordsRead":23804,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 21 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Brazil MTE employer register (lista suja)","readAt":"2026-10-21T10:00:17.817Z","recordsRead":508,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 21 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Brazil TCU (firms declared inidôneas)","readAt":"2026-10-22T12:30:23.053Z","recordsRead":94,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 22 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Canada Consolidated Autonomous Sanctions List","readAt":"2026-10-19T06:01:52.829Z","recordsRead":5708,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 19 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"EBRD Ineligible Entities","readAt":"2026-10-22T07:01:26.921Z","recordsRead":1278,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 22 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"ESMA Sanctions Register","readAt":"2026-10-23T12:00:38.517Z","recordsRead":845,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 23 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"EU Consolidated Sanctions List","readAt":"2026-10-19T04:32:49.638Z","recordsRead":6234,"publishedAt":"2026-10-15T10:10:34.160Z","publishedAtBasis":"stated_in_file","publisherVersion":"globalFileId 185699","publisherRecordCount":null,"daysOldWhenRead":4,"detail":null,"statement":"Read on 19 October 2026. The publisher dates the file 15 October 2026, 4 days before it was read."},{"source":"France AMF blacklist of unauthorised actors","readAt":"2026-10-23T11:09:40.219Z","recordsRead":2574,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 23 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"France Registre national des gels","readAt":"2026-10-19T09:31:48.168Z","recordsRead":2017,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 19 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"IDB Sanctioned Firms and Individuals","readAt":"2026-10-23T07:40:32.344Z","recordsRead":530,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 23 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Japan MOF Sanctions List","readAt":"2026-10-19T08:31:05.802Z","recordsRead":2900,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 19 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Latvia FID frozen assets register","readAt":"2026-10-20T06:00:31.335Z","recordsRead":183,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 20 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Malaysia BNM financial consumer alert list","readAt":"2026-10-19T11:00:24.650Z","recordsRead":588,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 19 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Malaysia SC investor alert list","readAt":"2026-10-19T09:01:15.606Z","recordsRead":1795,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 19 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Moldova procurement ban list","readAt":"2026-09-29T11:00:17.525Z","recordsRead":22,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 29 September 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"New Zealand Russia Sanctions Register","readAt":"2026-10-20T07:20:49.613Z","recordsRead":529,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 20 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Norges Bank (fund exclusions and observation)","readAt":"2026-10-20T10:00:22.713Z","recordsRead":201,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 20 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"OFAC Consolidated (non-SDN)","readAt":"2026-10-19T04:12:05.684Z","recordsRead":481,"publishedAt":"2026-09-14T00:00:00.000Z","publishedAtBasis":"stated_in_file","publisherVersion":null,"publisherRecordCount":481,"daysOldWhenRead":35,"detail":null,"statement":"Read on 19 October 2026. The publisher dates the file 14 September 2026, 35 days before it was read."},{"source":"OFAC SDN","readAt":"2026-10-19T04:11:19.630Z","recordsRead":17556,"publishedAt":"2026-10-15T00:00:00.000Z","publishedAtBasis":"stated_in_file","publisherVersion":null,"publisherRecordCount":19457,"daysOldWhenRead":4,"detail":null,"statement":"Read on 19 October 2026. The publisher dates the file 15 October 2026, 4 days before it was read."},{"source":"Poland MSWiA sanctions list","readAt":"2026-10-21T12:00:25.287Z","recordsRead":131,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 21 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"SAM.gov Exclusions (US federal)","readAt":"2026-10-24T06:06:25.724Z","recordsRead":10194,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 24 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Slovenia KPK business restrictions","readAt":"2026-10-15T11:03:08.201Z","recordsRead":4351,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 15 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Swiss FINMA warning list","readAt":"2026-10-19T06:17:48.138Z","recordsRead":2372,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 19 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Switzerland SECO Sanctions List","readAt":"2026-10-19T09:03:29.863Z","recordsRead":7040,"publishedAt":"2026-10-15T00:00:00.000Z","publishedAtBasis":"stated_in_file","publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":4,"detail":null,"statement":"Read on 19 October 2026. The publisher dates the file 15 October 2026, 4 days before it was read."},{"source":"Taiwan SHTC export entity list","readAt":"2026-10-21T12:32:56.889Z","recordsRead":11664,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 21 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Türkiye MASAK asset freezes","readAt":"2026-10-22T12:00:24.158Z","recordsRead":2304,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 22 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"UK OFSI Consolidated List","readAt":"2026-10-08T15:05:56.072Z","recordsRead":5120,"publishedAt":"2026-06-03T00:00:00.000Z","publishedAtBasis":"newest_record_date","publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":127,"detail":"Newest designation in the file: 2025-12-19.","statement":"Read on 8 October 2026. The file carries no date of its own; its newest record is dated 3 June 2026, 127 days before it was read. Newest designation in the file: 2025-12-19."},{"source":"UK Sanctions List (FCDO)","readAt":"2026-10-19T05:02:06.515Z","recordsRead":5705,"publishedAt":"2026-10-16T00:00:00.000Z","publishedAtBasis":"stated_in_file","publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":3,"detail":null,"statement":"Read on 19 October 2026. 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restrictions","status":"not_found","attemptedAt":"2026-10-15T11:02:47.854Z","listDatedAt":null,"listDateBasis":null},{"name":"Swiss FINMA warning list","status":"not_found","attemptedAt":"2026-10-19T06:17:33.311Z","listDatedAt":null,"listDateBasis":null},{"name":"US CBP forced-labour orders (WRO & Findings)","status":"not_found","attemptedAt":"2026-10-20T13:00:13.957Z","listDatedAt":null,"listDateBasis":null},{"name":"US UFLPA Entity List","status":"not_found","attemptedAt":"2026-10-20T09:00:16.451Z","listDatedAt":null,"listDateBasis":null},{"name":"World Bank Listing of Ineligible Firms and Individuals","status":"not_found","attemptedAt":"2026-10-23T07:00:40.321Z","listDatedAt":null,"listDateBasis":null}],"dimension":"debarment"}],"jurisdictions":[{"reasons":["registered here"],"countryId":"LV","registers":["Latvia Enterprise Register"],"ownershipRegisters":["Latvia Enterprise Register (members)"]}]},"ownership":null},"limits":["Whether each listing was in force is rebuilt from what was recorded here: when it was first read, when a source stopped or resumed carrying it, and when its published term ended. A listing in force at an authority before this system first read it is shown from that first read.","No ownership verdict is kept for this company. Verdicts are kept for companies registered where shareholders are read here: Estonia, Latvia and Poland."]}