SWEDEN Trends and Developments Contributed by: Viveka Classon, Karin Rättzén and Sara Stålebring, Advokatfirman Vinge KB
RiskPoint, DUAL, Ryan Specialty and Howden have strengthened their presence, while Nordic MGAs have developed strong profiles in areas such as financial lines, cyber, renewable energy, property, marine, liabil- ity and M&A risks. The MGA model enables faster product develop- ment under delegated authority, which suits risks that require rapid time to market and granular exper- tise, such as climate transition (renewables, energy storage, environmental liability), cyber, new mobility/ logistics, niche commercial risks and embedded dis- tribution. MGAs also act as channels for international capac- ity (including Lloyd’s) into the Nordics when Swedish insurers are selective in certain categories, such as large property or climate exposed assets. Proposed regulatory changes concerning unauthorised insur- ance activities may clarify the boundaries between delegated underwriting and unauthorised business, and are expected to increase compliance focus with- out changing the strategic role of MGAs. Overall, the MGA model is expected to continue to grow and professionalise in Sweden as insurers seek capital-light growth, brokers look for specialised underwriting partners, and clients demand tailored solutions in emerging risk areas. Updated Case Law – Anti-Money Laundry Risks When Paying Out Insurance Compensation According to the Swedish Law Regarding Criminal Liability for Money Laundering, criminal liability for commercial money laundering generally arises when an individual, within the course of business activities or on a larger scale, knowingly takes a risk in han- dling funds that may derive from crime, even if the transaction later turns out to be lawful. The decisive factor is whether the person recognised the risk and proceeded nonetheless.
Recent case law has sharpened the relevance of com- mercial money laundering for the insurance sector, particularly non-life insurance. In 2023, the Swedish Supreme Court considered two transfers from a law- yer’s client account executed on a client’s instruc- tions; the Court held that no one is obliged to carry out an act constituting a criminal offence, and found the lawyer criminally liable for money laundering. In 2025, the Court of Appeal underscored the implications for insurers, holding that a non-life insurer was entitled to refuse payment of a claim where the surrounding circumstances indicated a potential money launder- ing risk. In that case, concerning a fire-damaged car, suspicions arose from inadequate information about the purchase, the policyholder’s strained finances, and prior money laundering convictions. The Court found these factors sufficient to justify refusal of the claim. The case from 2025 has been appealed to the Supreme Court, but has not yet been ruled upon. These rulings matter for insurance companies in gen- eral, even though only life insurers are formally subject to the Swedish Anti–Money Laundering and Counter- Terrorist Financing Act. They indicate that insurers may, in certain circumstances, lawfully decline claim payments to avoid facilitating money laundering. The development also highlights a tension with the duty to contract ( kontraheringsplikt ) under the Swedish Insur- ance Contracts Act, which can require non-life insur- ers to accept customers even where money launder- ing concerns exist.
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