Protect your business against money laundering and financing of terrorism

Solicitors and law firms are subject to anti-money laundering legislation when they assist clients with certain financial transactions or in connection with the purchase and sale of businesses and property. If you carry out activities covered by the anti-money laundering legislation, you must comply with its requirements. This means you need to take action to prevent your business from being used for money laundering or the financing of terrorism.

What applies to solicitors at the Swedish Bar Association (in Swedish)

Conducting banking or financing business requires authorisation from the Swedish Financial Supervisory Authority (Finansinspektionen).

How to apply to carry out banking or financing business with the Swedish Financial Supervisory Authority (in Swedish)

Banks and credit institutions primarily engage in accepting deposits and providing loans. These companies may also offer financial services such as payments and transfers, securities transactions and card issuing. Banks process payments via payment systems and accept funds into accounts. Both banks and credit institutions accept repayable funds from the public, grant credit, provide credit guarantees, purchase receivables for financing purposes, or offer leasing.

Estate agents and real estate agencies are subject to anti‑money laundering legislation, and the Swedish Estate Agents Inspectorate (Fastighetsmäklarinspektionen) is the supervisory authority. As an estate agent, you often deal with clients in situations where large amounts of money change hands, making it important to work in a structured way to prevent money laundering.

To carry out insurance distribution, authorisation is required from the Swedish Financial Supervisory Authority (Finansinspektionen).
How to apply to carry out insurance distribution at the Swedish Financial Supervisory Authority (in Swedish)

Information about the authorisation

The authorisation to distribute insurance must be registered with the Swedish Companies Registration Office (Bolagsverket). Notification of registration must be submitted within six months of the authorisation being granted.

An insurance intermediary is a natural or legal person, other than an insurance undertaking or its employees, who, for remuneration, carries out insurance distribution.

Insurance distribution refers to activities that:

1. provide advice on or propose insurance contracts, or carry out preparatory work prior to the conclusion of a contract;
2. conclude an insurance contract; or
3. assist in the administration or performance of an insurance contract.

The Insurance Distribution Act at the Swedish Parliament

The Insurance Distribution Act (in Swedish)

Ordinance on Insurance Distribution (in Swedish)

Operating a pawnshop requires a sector-specific licence. The county in which your business is registered determines which County Administrative Board grants the licence.

Your business is subject to anti-money laundering legislation, as it may be used to conceal the illicit origin of money or other valuable items.

Three County Administrative Boards supervise how pawnshops comply with the regulations on money laundering and terrorist financing. More information about the anti-money laundering legislation and how to adopt a risk-based approach is available on the County Administrative Boards’ website.

The County Administrative Board in Skåne county (in Swedish)
The County Administrative Board in Stockholm county (in Swedish)
The County Administrative Board in Västra Götaland county (in Swedish)

Businesses that provide loans, other than pawnshops, are supervised by the Swedish Financial Supervisory Authority

Audit activities are subject to anti-money laundering legislation, as they may be used to conceal or process funds originating from criminal activity or used for terrorist financing.

“Auditor” is not a protected title, but being an authorised or approved auditor is. Only individuals who have passed the auditor’s examination (or aptitude test) administered by the Swedish Inspectorate of Auditors may hold the title of authorised or approved auditor. Authorised and approved auditors must be employed by an audit firm.

The Swedish Inspectorate of Auditors provides further information about authorised and approved auditors, audit firms, and obligations under the anti-money laundering legislation, as well as its supervisory activities in this area.

Money laundering and terrorist financing at the Swedish Inspectorate of Auditors (in Swedish)

For audit services provided by someone who is not an authorised or approved auditor, anti-money laundering supervision is carried out by the three County Administrative Boards.

Bookkeeping, accounting services and tax advisers

Gambling activities conducted under a licence or registration in accordance with the Gambling Act are, with certain exceptions for specific gambling services, subject to anti-money laundering legislation.

The Swedish Gambling Authority (Spelinspektionen) is the supervisory authority for operators holding a Swedish gambling licence and ensures that they comply with anti-money laundering requirements.

Anti-money laundering rules for licensed gambling operators at the Swedish Gambling Authority

A business that provides bookkeeping and accounting services not carried out by an authorised or approved auditor or a registered audit firm. A business that provides advice on taxes and charges.

A business that offers services to form a legal entity, sells newly established limited companies, or acts as an intermediary for Swedish or foreign legal entities.

A business that intermediates, stores or trades in works of art and receives or makes payments (regardless of the means of payment) amounting to EUR 10,000 or more. The amount may relate to one or several transactions that appear to be linked.

A business that provides legal advice and is not a solicitor or a law firm. The advice includes, among other things, assistance in planning and carrying out financial transactions, as well as transactions involving property or businesses on behalf of a client.

A business that provides registered office addresses or PO boxes, along with related ancillary services.

A business that provides any of the following services:

• administering a trust or a similar legal arrangement,
• acting as a nominee shareholder on behalf of another person,
• acting on behalf of a third party, for example as a director or partner in a company.

A business that sells or purchases goods for cash (banknotes and coins) amounting to EUR 5,000 or more. The amount may relate to one or several transactions that appear to be linked.