Banking Regulation 2025

SWEDEN Law and Practice Contributed by: Richard Engblom, Per Josephson, Anna Cumzelius and Amin Bell, Harvest Advokatbyrå

Harvest Advokatbyrå was established in 2016 and is Scandinavia’s largest independent spe - cialist law firm with a clear focus on advising financial institutions. Its 26-lawyer-strong bank - ing and finance team advises clients ranging from innovative start-ups, payment institutions, banks, fund managers and credit providers, to crypto-asset service providers and other com - panies active in the Swedish financial sector. It advises on a wide range of legal and financial regulatory issues important for the finance in - dustry, including compliance, internal audits, application procedures, AML/CTF, sustainable

finance, as well as on outsourcing of technol - ogy services by financial institutions. The firm maintains frequent and close contact with the Swedish Financial Supervisory Authority (Fi - nansinspektionen, SFSA) and a number of its employees are SFSA alumni. The scope of its services also includes advising companies in the banking and finance sector on corporate matters, such as setting up legal entities, trans - actional assistance, preparing and negotiating agreements, etc. The firm also advises on data privacy and data protection issues.

Authors

Richard Engblom is a senior associate at Harvest Advokatbyrå. He has considerable experience in financial regulation and compliance. He specialises in financial regulation, especially in the areas of banking regulation, payment services, consumer credits, securities, asset management, investment services, crypto- assets, AML/CFT, outsourcing and information security. In his work, Richard advises and assists a broad range of established financial institutions and fintech start-ups, such as payment institutions, banks, credit institutions, investment firms, fund managers and crypto- asset service providers, in matters relating to applications for authorisations, regulatory compliance and complex governance matters. Given his previous experience at the SFSA, he also regularly advises clients on financial sanctions issues and supervision.

Per Josephson is a senior associate at Harvest Advokatbyrå. He specialises in financial regulation, especially in the areas of asset fund management, asset

management, securities, sustainable finance and AML/CFT. In his daily work, Per provides advice on a variety of matters relating to authorisations with the SFSA and on various implementation projects, as well as corporate and contract law issues. Per has extensive experience in fund regulation, market abuse as well as sustainability regulation from the SFSA. Per is also a member of the board of Swesif, Sweden’s Sustainable Investment Forum, with the main responsibility of Swesif’s membership in Eurosif, a partnership of Europe-based national Sustainable Investment Fora (SIFs).

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