FINLAND Law and Practice Contributed by: Olli Kiuru, Jere Lehtimäki and Essi Hietaoja, Waselius
ment processor will need to be authorised by the FIN- FSA as a payment institution or a credit institution. 5.2 Regulation of Cross-Border Payments and Remittances At the EU level, payments and remittances are pri - marily regulated under PSD2. The Instant Payments Regulation (EU) 2024/886 accelerates the roll-out of instant payments and credit transfers denominated in euros within the EU. As of 9 October 2025, Finnish payment service providers have been obliged to offer and receive instant credit transfers. In addition to general legal requirements under PSD2, as transposed into the PSA and the PIA, cross-border payments are subject to specific information-reporting requirements under the Act governing the information- reporting requirement (659/2023), which implements Council Directive (EU) 2020/284. In Finland, the infor - mation shall be reported to the Finnish Tax Adminis - tration, which will deliver the collected information to the European Commission’s Central Electronic Sys - tem of Payments. Finland is also a member of the Single Euro Payments Area (SEPA), a payment-integration initiative of the EU that seeks to improve the efficiency of cross-border payments. Furthermore, money remittance activities, particularly those of the Hawala type, are generally considered to pose a high risk of money laundering and terrorist financing. In recent years, the FIN-FSA has strength - ened its supervisory measures for these companies, imposed penalty payments on those that fail to com - ply with the anti-money laundering and sanctions regulation, and even revoked the registration of some money remittance service providers. 6. Marketplaces, Exchanges and Trading Platforms 6.1 Permissible Trading Platforms The regulation of trading venues derives from MiFID II and covers regulated markets, multilateral trading facilities (MTFs) and organised trading facilities (OTFs). MTFs and OTFs are regulated nationally via Chap -
ter 5 of the Act on Trading in Financial Instruments (1070/2017), which provides the general requirements applicable to both trading venues. According to Sec - tion 1 of Chapter 5, in addition to the stock exchange, only investment firms, credit institutions and third- country branches may maintain MTFs and OTFs in Finland. MiCAR governs the operation of trading platforms for crypto-assets. A crypto-asset trading platform is a regulated entity under MiCAR that facilitates the trading of crypto-assets in a multilateral system that brings together multiple third-party buying and sell - ing interests. These platforms must be authorised as CASPs and comply with strict operational, organisa - tional and prudential requirements. 6.2 Regulation of Different Asset Classes In general, different asset classes do not have differ - ent regulatory regimes in Finland; rather, regulatory regimes are separated by the provision of certain services. For instance, offering investment services, regardless of the asset classes offered, requires an entity to be licensed under the MiFID II regime. Fur - thermore, an organiser of MTFs or OTFs can only be a credit institution, an investment firm, a branch of a licensed third-country company or a stock exchange. However, there are some regulatory differences – eg, between securities and other financial instruments. Financial instruments as a category includes securi - ties and financial instruments that are listed in the ISA. There is also some specific regulation on the issuance of securities, which is mainly contained in the Securi - ties Market Act (SMA, 746/2012). Furthermore, where the assets do not qualify as financial instruments but rather as crypto-assets, MiCAR governs the provision
of services related to such assets. 6.3 Impact of the Emergence of Cryptocurrency Exchanges
The emergence of crypto-assets has impacted the regulatory regime in Finland, mainly due to EU legis - lation governing crypto-asset exchanges. Operating trading platforms for crypto-assets or facilitating the exchange of crypto-assets for funds or other crypto- assets requires authorisation from the FIN-FSA under MiCAR and the ACASP.
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