SWEDEN Trends and Developments Contributed by: Richard Engblom, Per Josephson, Anna Cumzelius and Amin Bell, Harvest Advokatbyrå
tines for the validation process and measures for customer due diligence. The SFSA reviewed, among other things, the company’s general risk assessment, documen - tation regarding the company’s model for risk assessment of customers, routines for the vali - dation process as well as routines and guidelines regarding risk assessment of customers and customer due diligence measures. Furthermore, the SFSA reviewed a large number of customer files with associated documenta - tion. The SFSA selected customer files where, during the investigation period, the customers had generated alarms in the company’s transac - tion monitoring system or had been reported to the Police Authority for suspicious transactions or activities. In addition, the SFSA reviewed files for customers who were associated with one or more of the high-risk factors that Aros Kapital AB had indicated in its general risk assessment. With regard to the AML/CFT regulations, the SFSA identified shortcomings in the company’s general risk assessment, risk assessment of customers and measures for customer due dili - gence. Decision regarding Loomis Sverige AB (payment institution) In June 2024, the SFSA issued a remark and imposed a SEK40 million (approximately EUR3.6 million) administrative fine on the Swedish pay - ment institution Loomis Sverige AB. The SFSA investigated the company’s compliance with certain central provisions in the AML/CFT regu -
lations in its enumeration activities. The investi - gation showed that the company had violated several requirements. Loomis Sverige AB had deficiencies in its gen - eral risk assessment, which is of central impor - tance to the work of preventing money launder - ing. The assessment of geographical risks was insufficient and the company had not sufficiently considered which customers were engaged in cash-intensive businesses and the risks associ - ated with them. Furthermore, the company’s risk assessments of customers were insufficient, as the company had not made individual assessments of wheth- er the customers run cash-intensive businesses and what risks are associated with that type of operation. There were also deficiencies in the company’s basic and enhanced customer due diligence measures. In some cases, the compa - ny had not collected any information at all about its business relationships. During the investiga - tion period, Loomis Sverige AB had handled cash deposits of SEK11.7 billion from foreign banks, but had not taken sufficient measures to check the origin of these funds. Summary The SFSA has continued to actively supervise financial institutions with regard to AML/CFT compliance, resulting in hefty sanctions. Also, the SFSA’s position on general risk assessments has advanced. These are both clear signals that financial institutions need to make their AML/ CFT procedures a high priority to avoid being subject to fines and reputational risk.
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