Finland's measures to combat money laundering and terrorist financing

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MER Finland 2019

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Finland's measures to combat money laundering and terrorist financing

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


Download the report: 

MER Finland 2019

MER Finland 2019, Executive Summary

More information:  

The FATF Recommendations

FATF Methodology for assessing compliance with the FATF Recommendations and the effectiveness of AML/CFT systems

Consolidated assessment ratings - an overview of ratings that assessed countries obtained for effectiveness and technical compliance.

Key findings, ratings and priority actions: