Frequently asked questions – Prevention of money laundering and terrorist financing

Money laundering means concealing the origin of money where the money has been obtained by criminal means. Money laundering is always preceded by another crime, such as a financial or narcotics offence. By laundering money, criminals seek to make the proceeds of the preceding crime appear legal. 

Terrorist financing means the provision or collection of funds, directly or indirectly, to commit a terrorist offence. Financing or attempting to finance a terrorist group or an individual terrorist is punishable. Reports on suspected terrorist financing are received by the Financial Intelligence Unit (FIU) at the National Bureau of Investigation (NBI).

Money laundering is not always obvious or clearly noticeable, but its consequences are serious. As a result, it is important to be aware of the factors that may involve money laundering.

The following actions, for example, may indicate money laundering or terrorist financing:

• Unusual money transfers or transactions that do not appear to be compatible with the normal activities of a customer or person.
• Large cash deposits and unusually large account reserves for which no adequate and reliable explanation about the origin of the funds has been given
• The same person has opened several accounts into which numerous small deposits are made
• A person avoids answering or is clearly reluctant to answer questions related to assets
• Inconsistencies in information that may appear as illogicalities in documents submitted (including, for example, several identification documents used by the same person)
• Complex financing arrangements or transfers of funds that are intended to mislead third parties and conceal the origin of the funds
• The customer appeals to urgency and wishes business transactions to be handled with an exceptionally fast schedule
• Advance information provided by the customer and the purposes for the use of products or services do not correspond to actual use
• The occupation or salary income reported by the customer is not proportionate to the level or type of transactions
• The account holder is not engaged in business activities, but the account is used for various business-related transactions
• A number of people have access to an account, but they do not appear to have a family or business relationship with each other

Anti-money laundering supervision is based on a number of laws. The laws can be found on the Legislation page.

Gambling has been found to involve the risk of money laundering both at the international and national level. The risk of financing of terrorism has been found to be considerably lower in gambling than the risk of money laundering. Gambling and gambling operations can be exploited for example to conceal the origin of funds gained from illegal operations, or for the purpose of storing funds originating from illegal operations. It is important that the risks of misuse are taken into account in gambling operations and actively prevented, controlled and intervened with. Efficient prevention of money laundering and the financing of terrorism in all sectors is in the best interests of the society as a whole.

• Ministry of Finance
• Finnish Bar Association
• Border Guard
• Customs
• Regional State Administrative Agency of Southern Finland
• Financial Supervisory Authority
• National Bureau of Investigation / Financial Intelligence Unit
• National Police Board / Gambling Administration
• Finnish Patent and Registration Office
• Tax Administration
• Finnish Security Intelligence Service

• Financial Action Task Force (FATF)
• European Commission
• Council of the European Union
• European Securities and Markets Authority (ESMA)
• European Banking Authority (EBA)
• European Insurance and Occupational Pensions Authority (EIOPA)
• Nordic and Baltic financial supervisory authorities’ cooperation group

Obliged entities specified in the Money Laundering Act, such as banks and insurance companies, should establish, on the basis of a risk-based approach, their own customer due diligence procedures and minimum criteria to be followed in their customer relationships. The Money Laundering Act also provides for the duty of obliged entities to identify and know their customers and, if necessary, ascertain the origin of the funds included in a transaction. Obliged entities must also monitor the development of customer relationships and the use of services as part of the arrangement of business risks and internal control. Financial services used by customers, deposits, payment transactions, investment activity or the use of insurance services, for example, are monitored accordingly. Obliged entities also have an obligation to obtain information, which means that if an obliged entity detects an unusual or suspicious transaction, it must clarify the purpose of and justifications for the transaction and consider, on the basis of the clarification obtained, whether it is appropriate to make a report to the Financial Intelligence Unit.

The PRH registers details of beneficial owners with the Finnish Trade Register and discloses the details to parties using them in accordance with law. This concerns particularly supervisory authorities and parties subject to the reporting obligation. The PRH also has a role as a supervisory authority. The PRH monitors that auditors observe the obligations laid down in the Finnish Act on Money Laundering.

The Finnish Tax Administration has an obligation to notify the Financial Intelligence Unit of any suspicious transactions that may be related to money laundering or terrorist financing. In addition, the Finnish Tax Administration’s Grey Economy Information Unit prepares Compliance reports for use by other official authorities.

The Finnish Tax Administration is obligated to take the prevention and detection of money laundering and terrorist financing into account in its operations. The Finnish Tax Administration is not subject to the reporting obligation as defined by law, but it has general duty to exercise proper care and order of the Financial Intelligence Unit to report suspicious transactions. The Finnish Tax Administration therefore does report it if it detects any suspicious transactions that may be connected to money laundering or terrorist financing.

Suspicious transactions can be detected during any tax control measures, such as tax audits, registration procedures, the processing of tax returns and other filings or the monitoring of payment transactins. 

The Finnish Tax Administration is in active cooperation with other official authorities and different stakeholders both in Finland and internationally. Finnish Tax Administration personnel are trained in detecting money laundering and terrorist financing. The Finnish Tax Administration has used OECD’s handbook for detecting money laundering in its training, as well as a great number of other internal training materials.

The Finnish Tax Administration’s Grey Economy Information Unit prepares Compliance reports for use by other official authorities fighting money laundering and terrorist financing.

The indicators of money laundering are mostly the same as the indicators of shadow economy and economic crime. The Tax Administration takes money laundering into account in its activities for the prevention of shadow economy, in registration procedures, in the monitoring of shadow economy and in payment transactions in the same way as other criminal activities.

The Finnish Tax Administration may receive information about suspected offences predicate to illegal money laundering activities so that the related tax crime can be stopped, revealed and investigated. The Finnish Tax Administration cannot request information from the Financial Intelligence Unit.

The Finnish authority responsible for financial sanctions is the Ministry for Foreign Affairs. The Ministry’s website provides a lot of information about imposing and complying with sanctions. The National Enforcement Authority is responsible for the enforcement of sanctions. The police intervene in cases where there are indications that sanctions are circumvented.

Violating or attempting to violate sanctions constitutes a regulation offence under the Criminal Code. A suspicious transaction report must be made if such activity is detected. FIU Finland processes reports related to sanctions in an enhanced manner and disseminates information to, among others, the local police, Customs, Finnish Security Intelligence Service, enforcement authorities, and financial intelligence units in other countries.

The Border Guard's operations aim to detect indications of money laundering. Detections are usually made in connection with the Border Guard's border check or crime prevention tasks. If the Border Guard detects indications of money laundering during its operations, the processing of the matter will be transferred to the National Bureau of Investigation and Customs.

The National Bureau of Investigation makes a decision to freeze a person’s funds if the grounds for freezing funds provided in the Act on the Freezing of Funds with a View to Combating Terrorism are met. The National Bureau of Investigation must freeze a person’s funds if the person is reasonably suspected of, charged with or convicted of a terrorist offence.

The National Enforcement Authority is responsible for enforcing the decision and ensuring that it is not applied to funds needed for:

• covering foodstuff, housing and health care expenses or other similar necessary expenses of a natural person subject to the decision or of his or her dependants;

• paying taxes, charges comparable to a tax, charges imposed by authorities, compulsory insurance premiums or expenses for managing the funds;

• paying damages or fulfilling an obligation which arose before the decision to freeze the funds, provided that the funds of the recipient of the payment have not been frozen.

The ordinary consumer contributes best to the prevention of money laundering and terrorist financing by properly answering financial actors’ and authorities’ questions related to customer due diligence. Actors have a legal obligation to ask a customer questions, so the questions do not directly mean that the customer is suspected of involvement in money laundering or terrorist financing.

It is important for the consumer always to be prepared to contact with a low threshold their own service provider and, if necessary, the Police if they suspect fraud or other suspicious activity directed at financial services.

Private individuals can make a report anonymously via net tip on the Police website. 

A money laundering offence does not have to be intentional, since a person who through gross negligence undertakes actions that meet the criteria of money laundering may be punished for negligent money laundering. An example of such a case is a situation in which a person receives property in circumstances that differ so much from normal that the recipient has serious grounds to suspect the origin of the property.

By law, a bank and other obliged entity must retain the name of the document used to verify identity, the number or other identifying information of the document, and the issuer of the document. Alternatively, a copy of the document may be retained. A bank or, for example, an insurance company may therefore take a copy of the customer’s proof of identity.

Customer due diligence information and retention thereof in the Money Laundering Act (in Finnish)
 

The bank must identify its customer and verify the customer’s identity when establishing a regular customer relationship or at the latest before the customer receives funds or other assets included in a transaction or before a transaction has been completed. In addition, the bank must identify its customer and, if necessary, verify the customer’s identity in certain situations provided for in the Money Laundering Act or other laws regulating the financial sector, such as when a previous verification of identification has not been sufficient or the bank suspects its reliability. The bank must be able to indicate at a later date to the banking supervisory authority on which identification document the verification of the customer’s identity has been based.

Customer identification and verification of identity in the Money Laundering Act (in Finnish)

In the context of basic banking services, customer relationship means in which the customer only has a payment account, a payment card and access to online banking.

The following information is necessary and essential in establishing and maintaining a customer relationship involving basic banking services

• customer’s name, address, personal identity number and nationality
• information on whether the customer holds an important public position (politically exposed person, PEP) or whether he/she is a family member or a close associate of such a person
• information on the customer’s life situation, describing his/her financial status (e.g. employer, pensioner, student)
• information on whether the customer relationship to be established is the customer’s main banking customer relationship
• information on the origins or source of funds and regular payment transfers/cash flows
• assessment of the customer’s regular payment transaction volumes
• assessment of the customer’s foreign payment transaction volumes and the grounds for such transactions.

In customer relationships other than those involving basic banking services, the bank may be justified in requesting, in addition to the information referred to above, other information affecting customer due diligence. The necessity for such information depends on the nature and extent of the customer relationship.

Each bank or other obliged entity determines itself the questions related to ascertaining due diligence information to be asked of its customers. The law specifies the minimum information that the obliged entity must retain about its customer. In addition to the minimum information, the obliged entity may request other information from the customer if it deems it necessary to obtain the information based on its risk assessment.

The bank asks the customer for information on the use and intended use of banking services in order to be able to better assess what kind of use of banking services and what kind of payment transactions are the customer’s normal activity. By understanding the customer’s normal activity, it is possible to better identify unusual transactions and, if necessary, to ascertain the origin of the funds. It is the bank’s statutory duty to identify and investigate unusual transactions.
Obtaining information on the customer in the Money Laundering Act (in Finnish)
 

The bank or other obliged entity must keep all documents and information related to customer due diligence and transactions up-to-date and relevant. This requires that the information is reviewed and clarified at regular intervals. The bank or other obliged entity determines on a risk basis how often and in which situations information is requested from the customer.

Customer due diligence information and its retention in the Money Laundering Act (in Finnish)

The bank or other obliged entity is required by law to determine appropriately whether the customer or the customer’s beneficial owner at the time in question is or has been a politically exposed person, a family member of a politically exposed person, or a close associate of a politically exposed person. The bank or other obliged entity does not ask about the customer’s political position.

A politically exposed person and his or her family member and close associate are subject to enhanced customer due diligence, which is fulfilled by the bank or other obliged entity.

Enhanced customer due diligence related to a politically exposed person in the Money Laundering Act (in Finnish)

A comprehensive public register of politically exposed persons is not available. Politically exposed persons are found in most cases in public sources, but their close associates or business partners are often not found in these. The bank or other obliged entity therefore usually asks the customer about this directly.

The beneficial owner is the person who either owns the company or otherwise exercises control over the company. At least one of the following criteria must be met in order for a person to be considered the beneficial owner

• The person owns more than 25 per cent of the company’s shares directly, or indirectly via another company.
• The person holds more than 25 per cent of the voting rights in the company directly, or indirectly via another company.
• The person otherwise exercises effective control over the company.

Identification of beneficial owner in the Money Laundering Act (in Finnish)

Under the Money Laundering Act, banks, insurance companies and other financial actors are required to identify and know their customers and to collect information about them. Information on beneficial owners is part of the information collected on customers.

Customer due diligence information and its retention in the Money Laundering Act (in Finnish)

Most companies are required to make a Trade Register declaration of their actual beneficial owners and thereafter keep the information up to date in the Trade Register. The Finnish Patent and Registration Office (PRH) discloses the beneficial owner information entered in the Trade Register to the authorities and the Financial Intelligence Unit without alerting the entity in advance. Foreign supervisory authorities may also request information on actual beneficial owners directly from the PRH.

Banks and other obliged entities must identify the customer’s actual beneficial owners in order to fulfil customer due diligence. The PRH discloses, using a so-called beneficial owner extract, the information on a company’s registered beneficial owners to parties that use the information in accordance with law. In practice, these also include, in addition to the authorities, e.g. banks, insurance companies and other financial institutions that have a duty to fulfil customer due diligence. Obliged entities may use the information of the PRH’s beneficial owner extract when ascertaining the information on actual beneficial owners, but they cannot rely solely on the information on registered beneficial owners when fulfilling customer due diligence. In addition, obliged entities are required to notify the PRH if they perceive shortcomings or inconsistencies in the beneficial owner information entered in the Trade Register. The purpose of this is to ensure that the registered information on beneficial owners is correct and up to date.

Most companies, such as limited liability companies (excluding listed companies) and co-operatives, must file a free-of-charge notification of their beneficial owners. Private traders do not file a notification. Go to prh.fi and read more about companies that must file a notification of beneficial owners.

You must file a notification without delay in the following situations

• The company has not filed its beneficial owner details with the Finnish Trade Register between 1 July 2019 and 1 July 2020. 
• The beneficial owner details have changed. 
• A new company has been registered. 
• You are no longer a beneficial owner of the company. 

Please note: The company must file a notification of beneficial owners even if the company is of the opinion that it has no beneficial owners defined in the Finnish Act on Money Laundering.

File your notification online using the service at ytj.fi. The service is available in Finnish and in Swedish. Go to prh.fi and read the instructions on how to file a notification of beneficial owners.

An employee of the accounting firm can file the notification if you have authorised the employee to file Trade Register notifications on behalf of your company. You can give authorisations in the online service at ytj.fi. Read more about authorisations at ytj.fi.

After filing the notification, you must keep the details up to date. If the details change, file a new notification of beneficial owners. Go to prh.fi and read the instructions on how to file a notification of beneficial owners.

Information on whether the beneficial owner details have been filed is indicated on the company’s Trade Register extract and in Virre Information Service provided by the Finnish Patent and Registration Office (PRH). In Virre, you can search free of charge by using the Business ID. A submitted notification of beneficial owners is shown in the search result in the basic details of the company. Go to Virre Information Service.

In practice, it may become difficult for the company to carry out its operations if it does not file the notification. For example, banks, accounting firms and law firms are obligated to identify their customers and check the beneficial owner details. Under the Finnish Business Information Act, a fine can be imposed if the notification obligation is neglected. Filing incorrect information on purpose is a registration offence defined in the Finnish Criminal Code. Incomplete details or details that have changed must always be filed with the PRH without delay.

Banks and other obliged entities are required by law to ascertain and retain information on the name, date of birth and Finnish identity number of beneficial owners and, in the absence thereof, citizenship.

The beneficial owners of a non-profit association are considered to be the members of the board entered in the Register of Associations, for which reason the bank or other obliged entity must request and retain the information of each member of the board of an association.

Customer due diligence information and its retention in the Money Laundering Act (in Finnish)

Banks must have sufficient and up-to-date information on, among other things, the customer’s activities, financial position and the origin of the funds. If necessary, banks must also ascertain the origin and purpose of funds related to an individual transaction or the withdrawal or deposit of funds.

Banks must determine themselves the situations or the criteria on the basis of which the customer will be asked to clarify the origin and purpose of funds. Neither the Financial Supervisory Authority nor the legislator has issued a regulation on how large a cash withdrawal or cash deposit should be to initiate an enquiry related to the origin of funds; each bank determines such criteria itself.

The bank may also request later an explanation of the purpose of funds withdrawn from an ATM.

With receipts it is possible to show the origin of funds, which is why banks often ask for receipts in connection with cash deposits.

In addition, a bank may request from the customer written clarification of the origin of funds paid into an account as well as certificates on the customer's business, extracts from various registers, or other documents, such as bills of sale or a will.

Banks must have sufficient and up-to-date information on, among other things, the customer’s activities, financial position and the origin of the funds. If necessary, banks must also ascertain the origin and purpose of funds related to an individual transaction or the withdrawal or deposit of funds.

You can carry as much cash as you wish. If you are carrying 10 000 euros or more in cash and you enter or exit the territory of the EU, you must however declare your cash to Customs. 

As a task prescribed by law, Customs controls transports of cash and thereby prevents money laundering and financing of terrorism.

You can fill out a cash declaration on the Finnish Customs website before you travel, and print it out for presenting it to the customs authorities. If you need a declaration form, you can get one from Customs. You can then show your printed declaration and your cash to Customs when you leave the territory of the EU, or when you arrive there. For the time being, cash declarations cannot be submitted electronically.
 

If you are carrying 10 000 euros or more in cash, you should fill out the cash declaration form available on the Finnish Customs website, and then show the form and your cash to the customs authorities. In the form, you will be asked about your personal details, the origin of the money and its purpose of use, among other details. You should also find out about the regulations of your country of destination on bringing in cash.

Finnish Customs does not require a declaration when you are travelling within the EU territory. However, before your trip, you should find out about the regulations of your country of destination on bringing in cash. Some EU countries require you to declare your cash even if you are travelling within the EU territory. 
 

It does not make a difference whose money you are carrying. If you are carrying 10 000 euros or more in cash and you enter or exit the territory of the EU, you must declare all your cash to Customs. When you fill out the declaration form, you are required to give name of the person who owns the money. 

You may be fined. You may also be subject to criminal investigation and legal proceedings.

With receipts it is possible to show the origin of funds, which is why banks often ask for receipts in connection with cash deposits.

Banks must have sufficient and up-to-date information on, among other things, the customer’s activities, financial position and the origin of the funds. If necessary, banks must also ascertain the origin and purpose of funds related to an individual transaction or the withdrawal or deposit of funds.

Customer due diligence requires that the bank or other obliged entity knows on whose order and with whose funds transactions are made. Obliged entities have a statutory obligation to request from the customer information on the customer’s need to use the services as well as information on the customer’s activities, financial status and use of services.

In some situations, these clarifications may be referred to as a “money laundering form” or “money laundering questions”, even though they generally only concern the statutory collection of information required for customer due diligence.

The obliged entity is also entitled to enquire, if necessary, about the origin and purpose of funds paid into an account. A bank may, for example, request from the customer written clarification on the origin of funds paid into the customer’s account as well as certificates on the customer's business, extracts from various registers, or other documents, such as bills of sale or a will.

If the bank or other obliged entity does not receive from the customer the due diligence information required by the Money Laundering Act and information on the origin of funds, the bank or obliged entity may not establish a customer relationship, execute transactions or maintain a business relationship.

The bank, moreover, may not execute a payment transaction via a payment account if it does not receive sufficient information and clarifications from the customer.

Ultimately, the obliged entity may have to restrict the customer's use of services or terminate the customer relationship if the information is not received, because in that case the obliged entity is not permitted to execute transactions or maintain the customer relationship by law.

Customer due diligence in the Money Laundering Act (in Finnish)

In Finland, the gambling operator must identify the customer and verify the customer’s identity when bets are placed, if the financial input of the player totals, in single payment or in several linked payments, at least EUR 2,000. This limit of EUR 2,000 is laid down in the Act on Money Laundering and it is absolute. Moreover, the customer must be identified and the customer’s identity verified in situations of the transaction being suspicious, or if the gambling operator suspects that the assets involved in a transaction may be used for financing of terrorism or a punishable attempt of such an act. Because the identification and verification of identity in the aforementioned situations must be performed before the transaction is completed, the gambling operator must require the customer to present ID in connection with gambling.

In Finland, the gambling operator must identify the customer and verify the customer’s identity in connection with the payment of the winnings, if the winnings claimed by the player total, in one transaction or several linked transactions, at least EUR 2,000. This limit of EUR 2,000 is laid down in the Act on Money Laundering and it is absolute. Moreover, identity must be verified in situations where the transaction is suspicious, or if the gambling operator suspects that the assets involved in a transaction may be used for financing of terrorism or punishable attempt of such an National Police Board / Gambling Administration act. Because the identification and verification of identity in the aforementioned situations must be performed before the customer receives the funds involved in the transaction, the gambling operator must verify the customer’s identity before it pays the winnings to the customer.

A reporting entity must make a suspicious transaction report to the FIU if there is something suspicious about their customer’s activity. Such suspicions may include the following:

• The customer is reluctant to identify themselves.

• The requested transaction seems to have no business reason.

• The origin of the funds is suspicious.

• The customer attempts to circumvent sanctions.

• The contact person for the requested transaction does not seem to be the person who, based on the KYC and trade register information, should manage the company’s affairs.

A suspicious transaction report must also be made in cases where the transaction or customer relationship is refused. It is not possible to provide an exhaustive list of suspicious transactions as there are several dozen sectors that are subject to the reporting obligation, and the normal economic behaviour of different customer groups varies a lot from one customer and transaction type to another.

The customer due diligence obligation provided by the Act on Preventing Money Laundering and Terrorist Financing is crucial in identifying suspicious transactions. When a reporting entity knows the normal economic behaviour of their customer and that customer’s reference group, it is possible for them to identify unusual transactions and consider whether there is reason to make a suspicious transaction report.

Reporting entities are not responsible for proving that their customer’s activity involves money laundering or its predicate offence or terrorist financing; it is enough that they think that there is something suspicious about the activity from their perspective. A suspicious transaction report is thus not a report of an offence.

Obliged entities must immediately report a suspicious transaction or suspected terrorist financing to the Financial Intelligence Unit (FIU) at the National Bureau of Investigation (NBI). You can make the report online here. For a special reason, you may also submit your report using another secure connection or procedure.

The FIU does not inform the subject of a suspicious transaction report of the report made on them. The Act on the Financial Intelligence Unit provides that the name and identity of persons submitting suspicious transaction reports constitute confidential information.

The information may nonetheless be disclosed for the purposes specified in the Act, such as for the purpose of preventing, detecting and investigating money laundering and terrorist financing and such predicate offences as were or would have been committed to gain the assets or proceeds of crime subject to money laundering or terrorist financing, as well as for the purpose of referring cases for criminal investigation. In practice, this usually means criminal investigative measures. In criminal investigations opened on the basis of information provided by the FIU, the investigation team usually gathers supporting written evidence themselves, for example by means of bank inquiries.

For reports with indications of money laundering or its predicate offences or terrorist financing, the FIU opens a case to further investigate the matter. Where it appears that there is reason to suspect that an offence has been committed, the case is usually referred to the local police or the Criminal Investigation Division of the National Bureau of Investigation for criminal investigation. In criminal investigations, a suspicious transaction report is part of more comprehensive criminal investigation material that can include material obtained through coercive measures, written evidence and statements of witnesses, injured parties and the suspect.

In criminal cases, a suspicious transaction report may only rarely be used as sole evidence. The prosecutor examines the criminal investigation material and brings a charge if they consider that there are probable grounds to suspect that an offence has been committed. If a charge is brought, the case will be referred to a district court for hearing.  

There are a number of risk indicators to identify terrorist financing in a customer’s activity. In identifying terrorist financing, in particular, it is necessary to form an overall picture of the customer’s economic activity, as none of the unusual transactions mentioned below alone indicates terrorist financing. The monitoring of the customer’s account transactions may reveal, for example, an unusually large number of outdoor and combat gear purchases, purchases of chemical weapons, transactions related to the acquisition of dual-use goods, or other suspicious activity, such as unexpected withdrawal of the full balance of the account in cash.

Also, if a person receives several small sums on their account for no understandable reason, or there are other unexplained transactions on the account, this may be considered suspicious. Those involved in terrorist activities might transfer funds to their family and friends, who transfer these funds further, for example abroad or to domestic organisations whose purpose is not clear.

Geographical indicators can also be used; travelling or transferring funds to areas close to conflict zones might indicate support for a terrorist group. Conclusions made from services used by a customer can help identify terrorist financing and the fact that a person is leaving the country to become a foreign fighter. For example, buying life insurance or acquiring an all-terrain vehicle with financing from a finance company, together with other relevant indicators, might constitute suspicious activity in terms of terrorist financing.

In 2022, FIU Finland received around 230,000 suspicious transaction reports. Some reports are processed manually and some based on automated indicators set by the FIU.

In the case of reports with indications of money laundering or its predicate offences, terrorist financing or actions that might endanger national security, the FIU disseminates the information on the report further. If the information provided in the report is inadequate or may have links to a larger case, the FIU obtains additional information through national and international cooperation. FIU Finland disseminates information to, among others, the local police, Customs, National Security Intelligence Service, and financial intelligence units in other countries.

Private individuals can report facts related to money laundering or terrorist financing by sending an e-mail to [email protected] or by reporting non-urgent information about suspicious material or phenomena to the police on the online tip form.

RA reporting is done via the Reporter Portal of the Financial Supervisory Authority’s new Reporting System. Each reporter will see its own reporting obligations in the Reporter Portal.

More detailed instructions can be found on the Financial Supervisory Authority’s website.

Access authorisations for the Financial Supervisory Authority’s new Reporting System, will operate via the Suomi.fi e-Authorizations service, and reporters will manage the authorisations themselves.  
More detailed instructions can be found on the Financial Supervisory Authority’s website.

A zero report, i.e. No Reporting report, may be submitted by a reporter who does not have customers within the meaning of the Money Laundering Act or whose activities have not yet begun. If activities have ended, this must be reported to the Financial Supervisory Authority so that the reporting obligation can be deleted.

Reporting must always be done via the the Reporter Portal.

Apply for inclusion in the money laundering supervision register using the electronic application form at the address: https://sahkoinenasiointi.ahtp.fi/fi/palvelut.

If you notice that you have made a mistake in your registration form you can let us know by emailing [email protected]. We will then update your register entries.

To support our decision on registration we use an extract from the Trade Register and examine basic information of the enterprise. If changes are made in the basic information about a business entered in the Trade Register, the information is not updated in our supervision register. 

Changes to the company’s register data must be made using the notification form for changes that is available in the same customer service portal as the application for registration.

The amount of the fee collected for registering with the supervision register for money laundering has been set in the Government Decree on Fees for Regional State Administrative Agencies for 2019 and 2020 (1244/2018). As this involves a fee set in a decree the amount cannot be modified.

The obligations under the Money Laundering Act apply to both old and new clients, so the identities of old clients must be verified, if it has not been done earlier. Identity can be verified using a document such as a passport, or by using strong e-identification using banking codes, for example.

The information provider must retain the name of the client used in the verification of identity, the document number or other identification data, and the party granting the document or a copy of the document, or if the identity of the client is verified electronically, the information provider must retain the identification data of the procedure or source that was used.

If your old clients have already identified themselves electronically in such a way that the aforementioned identification information used in establishing identity has been saved and is in your possession, the verification of the identity of your clients already meets the requirements of the Money Laundering Act.

The Money Laundering Act includes a restriction provision under which it is not necessary to apply to join the supervision register if activities covered by the Money Laundering occur only sporadically, or to a very limited degree, and if all of the following criteria are met:

• The activity is minor, which means that the client's business activities do not exceed € 1,000.
• The activity is not the primary business activity of the company or person, and is an ancillary service directly related to it, whose share of turnover for the accounting period is no more than five percent.
• The primary business activity of the company is not within the scope of the Money Laundering Act.
• The activity is offered to clients of the primary business activity and it is not offered generally to the public at large.
• The activity does not involve money remittance of the kind mentioned in Section 1, Article 2, Part 5 of the Act on Payment Institutions.

As all the aforementioned conditions need to be met simultaneously, the limitation provision can be seen as quite strict. Consequently, a business operator who practices any activity defined in the Money Laundering Act, fundamentally falls within the scope of the Money Laundering Act. The State Administrative Agency has felt that the limitation provision can apply mainly to a larger enterprise whose primary business activity does not fall within the scope of the Money Laundering Act (for example, a real estate management office) and that a service offered to clients of this kind of business activity that falls under the Money laundering act (for example, an offer to do the bookkeeping of a housing company made to a real estate management client) is marginal, both with respect to the amount of money involved, and in comparison with the turnover of the company itself. Under Section 2 of Act 678/2017 of the Ministry of Finance, an activity is to be considered minor if the turnover of the client or that of the interlinked business activity generally falls below € 1,000.

All actors supervised by the Regional State Administrative Agency must be in a register maintained by the Regional State Administrative Agency. 

Only those actors who are not subject to supervision of an operating licence, or who are not required to register with another register maintained by a supervisory authority, need to register with the money laundering supervision register.

As your business is in another register maintained by a supervisory authority, you do not need to apply for the money laundering supervision register. On the other hand, merely being part of the Trade Register does not rule out an obligation to apply for inclusion in the money laundering supervision register.