The Financial Supervisory Authority has published a summary of its sanctions risk assessment
The Financial Supervisory Authority (FIN-FSA) has published a summary of its sanctions risk assessment for sectors supervised by the FIN-FSA under the Money Laundering Act. The sanctions risk assessment assesses for each sector the policies, procedures and internal controls in place to comply with sanctions regulations and national freezing orders in relation to the sector’s risk exposure. The sanctions risk assessment does not, however, assess the risk of different sectors acting in violation of sanctions.
According to the risk assessment, sanctions risk exposure has increased in sectors that offer various cross-border payment services enabling funds to be transferred quickly and easily from one place to another. These include, for example, credit and payment institutions that offer international payment services. These actors should pay particular attention to the level of their policies, procedures and internal controls. Money remittance and virtual currency service providers should also pay particular attention to ensuring that they have effective policies and procedures to comply with sanctions regulations.
The level of controls and the risks related to deficiencies in controls have been assessed in relation to the requirements set out in the Money Laundering Act and in the regulations and binding guidelines of the FIN-FSA. The level of controls has been assessed on the basis of information reported by supervised entities to the FIN-FSA in RA reporting as well as information obtained during supervision. It should be noted that FIN-FSA Regulations and guidelines 4/2023 Customer due diligence related to compliance with sanctions regulation and national freezing orders entered into force on 1 March 2024, i.e. only after supervised entities reported on sanctions-related controls in RA reporting for the first time.
An appendix related to sanctions evasion, published in connection with the summary of the sanctions risk assessment, collates information obtained through cooperation between authorities and from reliable public sources on identified ways of evading sanctions. The purpose of the appendix is to provide supervised entities with information they can utilise when preparing their own policies and procedures to prevent sanctions evasion.
The purpose of the sanctions risk assessment is to support the risk-based supervision of the FIN-FSA insofar as it concerns the supervision of compliance with the obligations set out in chapter 3, section 16 of the Money Laundering Act.
For further information, please contact
- Anssi Leisio, Chief Specialist, telephone +358 9 183 5524 or anssi.leisio(at)fiva.fi
- Viivi Jantunen, Senior Specialist, telephone +358 9 183 5008 or viivi.jantunen(at)fiva.fi
Appendices
See also