FI Supervision 1: Experiences from money laundering supervision 2016–2017

It is FI’s assessment that firms in general have a greater awareness of the regulations than in previous investigations and are committing more resources to their work to prevent money laundering. But more needs to be done.

FI presents in this report its observations from the supervision of the regulations regarding measures against money laundering and terrorist financing (money laundering regulations) conducted over the past few years.

During the period 2016-2017, FI investigated the compliance of approximately 70 banks, savings banks, credit market companies and money remitters with the money laundering regulations. The investigations were based on the previous regulatory framework from 2009, but the conclusions and guidelines set out in the report also apply under the new regulations that were introduced in 2017.

FI makes the assessment that the firms in general have established systems, procedures and documentation, but in several cases they had deficiencies in their analyses, assessments, follow-up and measures.

FI also makes the assessment that the firms' work to prevent money laundering and terrorist financing has improved in recent years. An area where the firms could further improve is to ensure that internal regulations and processes have been clearly tailored to their operations and have the intended effect. The work to prevent money laundering and terrorist financing must be continuous. In order for such efforts to have an impact, the entire chain of measures needs to be connected and constantly updated based on changing conditions. This is also a prerequisite for a monitoring system to be effective.

FI noted that the firms' general risk assessment does not always sufficiently identify the risks for all types of customers, products, services and distribution channels.

FI's investigations also showed that the firms do not always take sufficient measures to fulfil the customer due diligence requirements. For example, in several cases there was no information about the purpose and nature of transactions, risk classification of customers and beneficial owner.

Deviant behaviour or transactions that raise suspicions about money laundering must be reported to the Financial Intelligence Unit of the Swedish Police. FI noted that the firms' monitoring systems were not evaluated on a regular basis, which is necessary to identify and report deviant behaviour and transactions to the desired extent.


This is the first report in a numbered series that takes a closer look at conducted investigations and other supervision at FI. Through these reports, FI presents its observations and assessments as well as its expectations in various matters. This information can support firms in their operations.

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