Fintech 2025

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

Any such market maker must: • execute its market-maker strategy continu - ously during a fixed proportion of trading hours of the trading venue so that liquidity is provided to the trading venue in a regular and predictable manner; • enter into a written agreement with the opera - tor of the trading platform, which includes the market maker’s obligations; and • implement effective systems and controls to ensure that the institution always fulfils its contractual obligations with the platform operator. Market makers are obligated to maintain accu - rate and chronological records of all their placed or executed orders, and of prices quoted on trading venues. The company shall make these records available to the SFSA upon request. Furthermore, market makers must publish infor - mation on the quality of their execution of trans - actions. The information shall be published at least once a year and shall be made available free of charge. 7.3 Regulatory Distinction Between Funds and Dealers The rules regarding algorithmic trading, high- frequency trading and market making set out in the SMA apply to investment firms. 7.4 Regulation of Programmers and Programming Individual programmers that merely design and develop trading algorithms and other electronic trading tools are not subject to supervision or regulatory oversight. However, investment firms that utilise such programmes will have an obli - gation to ensure that such programmers have sufficient knowledge and experience to program

the tools and will also be responsible for the use and functioning of the tools.

8. Insurtech 8.1 Underwriting Processes

Insurance underwriting is the process of evaluat - ing risks to determine if the insurance company is able to issue insurance policies and the pricing of such policies. In their underwriting activities, insurance compa - nies must adhere to, for example, the IBA and the Swedish Insurance Contracts Act. These Acts contain provisions that largely cover the life span of an insurance policy, from inception until termination. The manufacturing of insurance products is also governed by the IDA and by Delegated Regula - tion (EU) 2017/2358 regarding product oversight and governance. 8.2 Treatment of Different Types of Insurance Insurance regulations generally distinguish between life insurance and non-life insurance. For example, different capital requirements apply for life insurers and non-life insurers, and only life insurance operations are in scope of the Swedish Anti-Money Laundering Act. There are also noteworthy differences in regu - lation and treatment depending on whether an insurance policy is issued to a consumer or to a company.

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