Fintech 2026

SWEDEN Law and Practice Contributed by: Robert Karlsson, Helena Rönqvist, Caroline Landerfors and Vilma Slättegård, Magnusson Law

a Swedish AI Law, complementary to the AI Act. The proposal is expected to be published in spring 2026. 2.12 Review of Industry Participants by Parties Other Than Regulators The supervision of regulated financial companies, including fintech companies, is mainly carried out by public regulators. There are several industry associations on the finan - cial market, such as the Swedish Securities Markets Association, the Swedish Banker’s Association, Insur - ance Sweden and the Swedish Investment Fund Asso - ciation. Most industry associations do not supervise their members but rather represent them and strive to contribute to a sound and efficient financial market, and to promote sound and proportional regulations. In 2017, a specific industry association for fintech companies, the Swedish FinTech Association, was founded. The mission of the Swedish FinTech Asso - ciation is to increase the understanding of fintech of both decision-makers and authorities by initiating meetings, contributing to consultation responses and speaking to relevant government officials. The Swedish FinTech Association has as members fintech companies operating in the following areas: payments and transfers, lending, wealth and cash management, cloud services and regtech, crowdfunding and block - chain, investment, trading and advisory. Most financial companies are obliged to have a certi - fied auditor who is tasked with reporting suspected crimes under, for instance, the Penal Code, the Tax Crimes Act and the Money Laundering Crimes Act. 2.13 Conjunction of Unregulated and Regulated Products and Services For a number of financial companies, such as invest - ment firms, credit institutions and insurance compa - nies, there are various regulations that limit or prevent the provision of unregulated products and services in conjunction with regulated activities. Regulated and unregulated products and services are not bundled to any greater extent on the financial mar - ket. However, some regulated companies may work together with co-operative partners to provide unreg -

ulated products and services, while others decide to enter the market with a “lighter authorisation”. For instance, start-up insurtech companies may enter the market by becoming a tied insurance intermediary instead of applying for authorisation as an insurance company. Similarly, a company that intends to pro - vide fintech services that are regulated as investment services may enter the market by becoming a tied agent (to an investment firm) rather than applying for authorisation from the SFSA. 2.14 Impact of AML and Sanctions Rules AML and sanctions rules and regulations impact fin - tech companies to a great extent. AML has been a focus area for the SFSA’s supervision and sanctioning activities for the last several years. The Anti-Money Laundering and Counter Terrorist Financing Act (the “AML Act”) and the connected AML regulations from the SFSA apply to the absolute majority of regulated fintech companies in Sweden. Fintech companies that are subject to the AML Act and the AML regulations must carry out AML risk assess - ments and adopt appropriate AML policies, covering areas such as know-your-customer controls, risk clas - sifications and customer and transaction monitoring. On 30 December 2024, the Regulation (EU) 2023/1113 on Revised Transfer of Funds (TFR), aimed at prevent - ing money laundering and terrorist financing, became applicable. The revision has an extended scope, cov - ering transfers of crypto-assets. Furthermore, the SFSA has announced that it will apply the updated EBA Guidelines (EBA/GL/2024/01) on risk factors for money laundering and terrorist financing regarding crypto-assets and crypto-service providers. 2.15 Financial Action Task Force (FATF) Standards Sweden became a member of the Financial Action Task Force (FATF) in 1990. By being a member of the FATF, Sweden has undertaken to implement the standards imposed by the FATF into the Swedish legal system.

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