Finland's measures to combat money laundering and terrorist financing

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Language

English

Country

Finland

Mutual Evaluation Finland

MER Finland 2019

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Paris, 16 April 2019 - Finland’s measures to combat money laundering and terrorist financing are delivering good results, but the country needs to improve supervision.

The FATF assessed Finland’s anti-money laundering and counter terrorist financing (AML/CFT) system. The assessment is a comprehensive review of the effectiveness of Finland’s measures and their level of compliance with the FATF Recommendations. Finland has a sound framework to combat money laundering and terrorist financing which is delivering some good results, but there are some areas to improve the effectiveness of the country’s framework, especially with regard to the AML/CFT supervision of financial and non-financial institutions.

The money laundering risk in Finland comes primarily from the grey economy, but also from domestic and foreign frauds and the proceeds of drug crimes.  The main terrorist financing risks in Finland stem from sympathisers of terrorist causes and foreign terrorist fighters, in particular ISIL’s foreign terrorist fighters (FTF) and returnees.  Finland’s authorities have an adequate level of understanding of these risks, and are addressing them in a well-coordinated manner. Regarding terrorist financing risks though, the changing environment, with increased focus on ISIL FTF and returnees, is not adequately reflected in terrorist financing cases investigated.

Finland’s authorities cooperate routinely with foreign counterparts, sharing timely and accurate information and conducting complex and international money laundering investigations.   Authorities make good use of financial intelligence to develop evidence and trace criminal proceeds but can improve the use of analysis produced by the financial intelligence unit and access to beneficial ownership information.  Finland has the legal framework to recover assets. However, Finland does not demonstrate whether the policies are actually successful in permanently depriving criminals of their assets.

Financial institutions have an adequate understanding of their exposure to money laundering risks and the steps they need to take to mitigate these risks, but there are some gaps when it comes to terrorist financing risks.  The level of understanding of these risks is fragmented across designated non-financial businesses and professions and they do not, or rarely, report suspicious transactions for further investigation. The supervisors need to improve the risk-based supervision of all of these sectors and require a significant increase in resources.

FATF adopted this report at its February 2019 Plenary meeting.

Executive Summary - Mutual Evaluation Report Finland

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MER-Finland-2019-Executive-Summary.pdf
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Press Release by the Ministry of the Interior of Finland: “Finland to step up efforts to combat money laundering and terrorist financing"

Press Release by the Financial Supervisory Authority: "Financial Supervisory Authority strengthens anti-money laundering supervision – European supervision will also be enhanced”

Technical Compliance

Ratings which reflect the extent to which a country has implemented the technical requirements of the FATF Recommendations.

Finland Mutual Evaluation 2019

R.1 - Assessing risk & applying risk-based approach
LC
R.2 - National cooperation and coordination
PC
R.3 - Money laundering offence
LC
R.4 - Confiscation and provisional measures
LC
R.5 - Terrorist financing offence
LC
R.6 - Targeted financial sanctions related to terrorism & terrorist financing
LC
R.7 - Targeted financial sanctions related to proliferation
LC
R.8 - Non-profit organisations
PC
R.9 - Financial institution secrecy laws
C
R.10 - Customer due diligence
LC
R.11 - Record keeping
C
R.12 - Politically exposed persons
LC
R.13 - Correspondent banking
PC
R.14 - Money or value transfer services
C
R.15 - New technologies
LC
R.16 - Wire transfers
C
R.17 - Reliance on third parties
LC
R.18 - Internal controls and foreign branches and subsidiaries
LC
R.19 - Higher-risk countries
PC
R.20 - Reporting of suspicious transactions
C
R.21 - Tipping-off and confidentiality
C
R.22 - DNFBPs: Customer due diligence
LC
R.23 - DNFBPs: Other measures
LC
R.24 - Transparency and beneficial ownership of legal persons
PC
R.25 - Transparency and beneficial ownership of legal arrangements
LC
R.26 - Regulation and supervision of financial institutions
LC
R.27 - Powers of supervisors
PC
R.28 - Regulation and supervision of DNFBPs
PC
R.29 - Financial intelligence units
C
R.30 - Responsibilities of law enforcement and investigative authorities
C
R.31 - Powers of law enforcement and investigative authorities
LC
R.32 - Cash couriers
LC
R.33 - Statistics
LC
R.34 - Guidance and feedback
PC
R.35- Sanctions
PC
R.36 - International instruments
LC
R.37 - Mutual legal assistance
LC
R.38 - Mutual legal assistance: freezing and confiscation
LC
R.39 - Extradition
LC
R.40 - Other forms of international cooperation
LC

C = compliant   |   LC = largely compliant     |   PC = partially compliant   |   NC = non-compliant

Effectiveness

Ratings that reflect the extent to which a country's measures are effective. The assessment is conducted on the basis of 11 immediate outcomes, which represent key goals that an effective AML/CFT system should achieve.

Ratings that reflect the extent to which a country's measures are effective. The assessment is conducted on the basis of 11 immediate outcomes, which represent key goals that an effective AML/CFT system should achieve.

Finland Mutual Evaluation 2019

IO1
SE
IO2
HE
IO3
LE
IO4
ME
IO5
ME
IO6
SE
IO7
SE
IO8
ME
IO9
ME
IO10
ME
IO11
ME

HE = high level of effectiveness   |   SE = substantial level of effectiveness    |   ME = moderate level of effectiveness   |   LE = low level of effectiveness

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