Swedbank Financial Crime Risk Statement

The FC Policy Statement in brief

Financial Crime poses a serious threat to the security and integrity of the global financial system. Swedbank has regulatory, moral, and social obligations to its customers, shareholders, and regulators to maintain an effective and robust response to the risks of Financial Crime. The prevention of Money Laundering, Terrorist Financing, Financial Sanctions violations, Bribery and Corruption, and Tax Evasion, collectively referred to as Financial Crime, is therefore a prioritised focus area within Swedbank and by its senior management.

Swedbank is committed to complying with applicable Financial Crime laws and regulations in the jurisdictions in which the Group operates.
Swedbank has established a Financial Crime Compliance (FCC) Programme that ensures adherence to these commitments through a risk-based approach. The Programme articulates and outlines the overall response or approach taken across all three lines of defence in Swedbank Group to identify, assess and adequately manage the relevant FC risk exposure that exists. The program aims to prevent criminal misuse of Swedbank’s systems, products, and services and ensure compliance with commitments and a risk-based approach in all business activities.

Swedbank has a low Risk Appetite, with respect to the relevant Financial Crime risks. This determines the nature and level of Financial Crime risks that Swedbank is willing to accept to be consistent with the low risk profile.

Situations related to transactions, services, products, and customer relationships that fall outside this Risk Appetite are not tolerated.
To define the boundaries of the Risk Appetite, Swedbank has identified and outlined prohibited activities, behaviours, and situations where risks are unacceptable or cannot be effectively managed or mitigated. In these cases, Swedbank will not establish or maintain business relationships, nor perform any transactions.

Financial Crime Compliance Programme

The commitment and support of the senior management and an effective governance outlining clearly defined roles and responsibilities across the Group is essential for the success of the FCC Programme. The elements of Swedbank's FCC Programme are designed to interconnect and reinforce one another, where each component plays a critical role in ensuring the overall effectiveness of the programme.

The Enterprise-Wide Risk Assessment (EWRA) is a proactive, quantitative approach designed to identify and assess risks across Swedbank. It forms the foundation for the FCC Programme by informing the design and scope of internal controls, policies and procedures on all levels. The EWRA enables Swedbank to apply a risk-based approach, where measures are proportionate to the identified risks — higher risks receive enhanced mitigation efforts while lower risks are managed accordingly. By continuously steering the direction of these elements, based on current risk assessment, Swedbank ensures that its compliance efforts are aligned with its stated risk appetite.

A robust internal control environment is crucial for effective implementation of the FCC Programme. The control environment, including policies and procedures, is designed to direct and support a risk-based approach throughout Swedbank. Internal controls aim to mitigate inherent risks identified by EWRA by establishing clear processes for preventing, identifying, blocking, escalating, reporting and recording suspicious activities that may breach regulations or laws. These controls ensure that regulatory requirements are adhered to while providing a structured approach to managing financial crime risks effectively.

Testing and Auditing activities provide objective quality assurance across all elements of the programme and involve all three lines of defence within Swedbank — each playing a specific role in identifying weaknesses or deficiencies. Ongoing testing ensures that potential gaps or shortcomings in compliance measures are detected early and addressed promptly. The primary objectives include evaluating whether first line of defence operations comply with regulatory obligations, assessing the effectiveness of internal policies and control measures in managing compliance risk, and performing model validations.

Training employees thoroughly on FC prevention is fundamental to cultivate a strong compliance culture at Swedbank. A forward-looking approach characterised by risk awareness involves providing mandatory e-learning for all staff members as well as dedicated training tailored specifically for those handling financial crime risk tasks or assigned certain roles within this domain. Additionally, ad-hoc training sessions address specific events or needs involving staff, clients, or other stakeholders. Building such a knowledgeable workforce ensures that employees understand their responsibilities regarding financial crime prevention while fostering an environment where compliance is valued highly.

Together, these components form a unified system and creates a comprehensive defence mechanism against FC risk. This approach not only enhances Swedbank’s ability to detect and prevent illicit activities but also ensures ongoing compliance with regulatory standards, thereby safeguarding Swedbank’s operations and its reputation.

More information may be found in the Swedbank Wolfsberg Questionnaire.

Swedbank Wolfsberg Questionnaire (PDF).

Swedbank Financial Crime Risk Statement

The FC Policy Statement in brief

Financial Crime Compliance Programme

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