FINLAND Law and Practice Contributed by: Olli Kiuru, Jere Lehtimäki and Essi Hietaoja, Waselius
potential impacts that might ensue from regulation, and it provides expert opinions on legislative pro - cesses. The organisation of FFI is divided into five groups, of which the Infrastructure and Security group is concerned with fintech. The Fintech Finland Association (a non-profit organi - sation comprised of stakeholders in the Finnish fin - tech ecosystem) is another relevant party reviewing the activities of fintech companies – for instance, by actively promoting the interests of the Finnish fintech industry. 2.13 Conjunction of Unregulated and Regulated Products and Services The offering of unregulated products or bundling them together with regulated products and/or services is not that common in Finland. If such an offering were to exist, it would likely be conducted by a regulated entity due to regulatory concerns. 2.14 Impact of AML and Sanctions Rules The Finnish AML Act imposes a variety of obligations upon obliged entities, including: • “know your customer” procedures; • record-keeping; • ongoing monitoring; and • identifying beneficial owners. In accordance with the AML Act, obliged entities are financial market players such as fintech entities engaging in payments and financing, wealth manag - ers, fund companies and CASPs. Know Your Customer Obliged entities must identify their customers prior to forming permanent customer relationships. However, obliged entities will also be required to identify their customers when forming occasional customer rela - tionships if the conditions set forth in the AML Act are fulfilled. If an obliged entity fails to identify its customer to the extent stipulated in the AML Act, it will be prohibited from forming a customer relationship and carrying out the business operation, and from maintaining the business relationship.
Depending on the customer, obliged entities must identify their customers by means of a simplified or enhanced due diligence procedure. Government Decree 929/2021 lays down the due diligence pro - cedures that must be undertaken when identifying customers, particularly in relation to simplified and enhanced due diligence procedures. The AML Act does not necessarily apply to many unregulated fintech companies, but its applicability should be assessed in detail before excluding the ser - vices and/or products outside the scope of the AML Act. Sanctions Regulation and National Freezing Orders The FIN-FSA’s Regulations and Guidelines 4/2023 on customer due diligence related to compliance with sanctions regulation and national freezing orders entered into force on 1 March 2024 and imposed new requirements on various financial entities. Regulations and Guidelines are provided on the organisation of the supervised entity’s activities, assessment of risks related to sanctions, customer due diligence, sanc - tions screening, asset freezing, third-country sanc - tions and reporting. New rules on sanctions crime in the Finnish Criminal Code (39/1889) entered into force on 20 May 2025. If a company is found guilty of a sanctions-related crime, a maximum corporate fine of EUR40 million may be imposed. 2.15 Financial Action Task Force (FATF) Standards In its 2019 country assessment of the prevention of money laundering and terrorist financing, the FATF identified several areas for Finland to improve. Since then, Finland has made significant progress in enhancing its compliance with the FATF’s standards by amending its anti-money laundering and sanc - tions rules, and the country is no longer subject to the enhanced follow-up process. Today, Finland is either compliant or largely compliant on most of the recom -
mendations issued by the FATF. 2.16 Reverse Solicitation
Reverse solicitation is available when offering financial products or services cross-border to Finland. Informa - tion/services/products provided to the Finnish client/
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