COBALT advises Latvian banks on agreement to ensure accessibility of cash

Four Latvian retail banks — Swedbank, SEB, Luminor and Citadele — have agreed on cooperation to ensure good coverage of cash services throughout Latvia. The memorandum signed on 3 September provides, among other things, for the availability of an ATM within 20 km from the home of at least 99 percent of population.

The increasing proportion of electronic payments has lowered both the demand for cash and the importance of ATMs in competition among banks. Yet, availability of cash remains important from a social perspective and has implications for privacy.

The largest retail banks have recognised a potential for voluntary cooperation in order to maintain, by means that would serve both consumer interests and cost efficiency, a certain level of service standards that were set in collaboration with the Bank of Latvia.

Under the auspices of the Finance Latvia Association, COBALT assisted in the drafting of the cooperation memorandum, ensured competition law compliance in the meetings among the parties, and helped obtain a comfort letter from the Latvian competition authority. The assignment was led by Edgars Pastars, Specialist Counsel, and Ugis Zeltins, Partner.