Scope

Swedbank's AML and CTF Policy applies for Swedbank AB and all subsidiaries.

The policy in brief

Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) are prioritised focus areas within Swedbank. Money laundering and terrorist financing activities are threats to the integrity and the stability of the international financial system. Financial institutions must be able to identify and understand risks of money-laundering and terrorist financing to apply preventive measures.

Swedbank has a responsibility to its customers, shareholders, and regulators to prevent the Group from being used to facilitate the movement of criminal proceeds or transfer of funds destined to finance terrorism.

The Group is committed to identifying and managing the money laundering and terrorist financing risks that it is exposed to and to take proportionate measures required to manage these risks across all jurisdictions in which it operates. Therefore, the Group shall apply robust and consistent Anti-Money Laundering and Counter Terrorist Financing standards and procedures to prevent the use of products, services, or channels for purposes of money laundering and terrorist financing in the jurisdictions in which it operates.

Preventative measures

Given that criminals may use financial services to launder money to fund their criminal activities, proper Know-Your-Customer (KYC) practices are central. Knowledge of the customer helps us understand the general activities in which the customer would usually be expected to engage. As a bank, we are required to detect unusual and suspicious activities and to determine whether a specific customer is present on various sanctions lists.

Money-laundering and terrorism not only harm the whole society but can also damage the stability and reputation of the financial sector. It is obviously in the financial industries and society's best interests that financial institutions take all reasonable measures to prevent money-laundering and terrorist financing. To detect money laundering, Swedbank cooperate with a number of actors, including other banks, authorities, and the police. Swedbank also has, among others, the following procedures in place:

  • Swedbank has adopted a Policy on prevention of money-laundering and counter-terrorist financing that requires all parts of the Swedbank Group to develop and implement effective programs to comply with applicable laws.
  • Customer Due Diligence (CDD) includes, among other things, identifying the customer and verifying the customer’s identity on the basis of documents, data or information obtained from reliable and independent sources. We also need to understand the ownership and control structure of our customers. 
  • The Group performs daily screening of the customer base against financial sanctions and PEP¹ lists. All international payments are also screened in real time regarding financial sanctions.
  • The initiation or maintenance of a business relationship with a PEP¹ or other relevant high-risk customer needs to be approved by an authorised decision-maker.

¹Person in politically exposed position (or PEP, from the English term Politically Exposed Person). A person in a politically exposed position, and the family members and well-known colleagues of this person, through their position and influence, are considered to have a position which in itself constitutes a risk of being exploited for, among other things, bribery.