Higher Risk
 
Medium Risk
 
Info n/a
 
Lower Risk
Sanctions:

As a member of the EU, the country is party to all EU Sanctions
as well as UN sanctions.

____________________________________________________

Offshore Jurisdiction Blacklists:

Information unavailable.

____________________________________________________

US State Department Money Laundering Report - 2011:

Finland is not a regional financial center. Over the past decade,
Finland repeatedly has placed first or second on Transparency
International’s Corruption Perceptions Index (CPI); in 2010,
Finland ranked fourth on the list. The major sources of illegal
proceeds in Finland relate to financial crimes and the majority of
suspicious financial activities investigated have an international
dimension. These funds are normally laundered through currency
exchanges and gambling establishments. The number of
organized crime groups has grown slightly in the past few years,
as has the number of their members. Terrorism related fund-
raising, to the extent it exists, appears to be less of a problem
than in other European countries.

Finland has free zones in Hanko, Hamina, Lappeenranta and
Turku, and free warehouse areas in Kemi and Oulu. Goods may
be stored for an unlimited time in these zones without customs
clearance, but they may not be consumed or sold on a retail
basis. The same tax and labor laws apply to free zones/free
warehouses as to other workplaces in Finland.

DO FINANCIAL INSTITUTIONS ENGAGE IN CURRENCY
TRANSACTIONS RELATED TO INTERNATIONAL NARCOTICS
TRAFFICKING THAT INCLUDE SIGNIFICANT AMOUNTS OF US
CURRENCY; CURRENCY DERIVED FROM ILLEGAL SALES IN
THE U.S.; OR THAT OTHERWISE SIGNIFICANTLY AFFECT THE
U.S.: NO

CRIMINALIZATION OF MONEY LAUNDERING:

“All serious crimes” approach or “list” approach to predicate
crimes: All serious crimes

Legal persons covered: criminally: YES civilly: YES

CRIMINALIZATION OF TERRORIST FINANCING:

Ability to freeze terrorist assets without delay: YES

UN lists of designated terrorists or terrorist entities distributed to
financial institutions: YES

(Please refer to the Department of State’s Country Reports on
Terrorism, which can be found here: http://www.state.
gov/s/ct/rls/crt/)

KNOW-YOUR-CUSTOMER RULES:

Covered entities: Banks and financing institutions and financial
holding companies; investment firms; fund management
companies and custodians; the central securities depository; book
entry registrars; real estate agents and apartment rental
agencies; gaming entities; insurance companies and
intermediaries, and local mutual insurance associations;
pawnshops, auctioneers, and dealers in vehicles and high value
goods; auditors, accountants, and lawyers

Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: NO

SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:

Covered entities: Banks, credit and financial institutions,
investment and fund management companies; insurance brokers
and insurance companies; real estate agents and apartment
rental agencies; betting services and casinos; management
companies; custodians of mutual funds; auditors, lawyers, tax
advisors, and accountants, auctioneers, pawn shops, and dealers
in vehicles and high value goods; businesses and professions
that perform other payment transfers, such as hawala;
repossession agents and bankruptcy ombudsmen

Number of STRs received and time frame: 12,375 January - June
2010

Number of CTRs received and time frame: Not applicable

MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:

Prosecutions: 18 in 2008

Convictions: None

Assets forfeited: criminally: Not available civilly: Not applicable

RECORDS EXCHANGE MECHANISM:

With U.S.: YES

With other governments/jurisdictions: YES

Finland is a member of the Financial Action Task Force. Its most
recent mutual evaluation can be found here: http://www.fatf-gafi.
org/document/58/0,3343,
en_32250379_32236963_39535482_1_1_1_1,00.html

ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:

The Government of Finland has a comprehensive anti-money
laundering/counter-terrorist financing regime and should continue
to enhance its laws and regulations as necessary to adhere to
international standards.

Finland has, in conjunction with the other Nordic Countries,
prepared and concluded treaties with certain offshore financial
centers concerning the exchange of information on tax related
matters. The treaties are part of the tax haven project, set out by
The Nordic Council of Ministers. Finland has signed bilateral
treaties on information exchange and taxation with Montserrat and
Liberia (November 2010), Vanuatu (October 2010), Marshall
Islands (September 2010), Belize (September 2010), Monaco
(June 2010), Antigua and Barbuda, Dominica , Grenada, Saint
Lucia (May 2010), St. Vincent and the Grenadines , St Kitts and
Nevis, Bahamas (March 2010), Andorra (February 2010), San
Marino (January 2010), Cook Islands, Samoa, Turks & Caicos,
Anguilla (December 2009), Gibraltar (October 2009), Aruba and
Netherlands Antilles (September 2009), British Virgin Islands (May
2009), Bermuda and Cayman Islands (April 2009), Jersey and
Guernsey (October 2008) and Isle of Man (October 2007).

In June 2010 the Financial Supervision Authority (FSA) issued
updated customer due diligence standards effective September 1,
2010, applicable to all entities regulated by the FSA.

____________________________________________________

US State Dept Narcotics Report 2011 (introduction):

No report available

____________________________________________________

US State Dept Trafficking in Persons Report 2011
(introduction):

(Tier 1)

Finland is a transit and destination country for women and girls
subjected to sex trafficking, and for men and women subjected to
conditions of forced labor. Female sex trafficking victims originate
in Russia, the Baltic countries, the Caucasus, Asia, Africa, Central
Eastern Europe, and the Caribbean; forced labor victims come
primarily from India, China, Thailand, Pakistan, and Bangladesh.
Forced labor victims are exploited in the construction industry,
restaurants, agriculture, in berry picking fields, and as cleaners
and domestic servants. There were indications that forced
begging was also a problem during the reporting period. There
were reports that migrants who had voluntarily traveled to Finland
were coerced to work long hours for minimal wages through
threats of violence and other means of control; Finnish authorities
believed there were likely small numbers of trafficked workers in
most major Finnish cities. The Finnish National Rapporteur on
Trafficking in Human Beings and NGOs suspected au pairs,
foreign students, and asylum seekers were vulnerable to
trafficking. Some Finnish teenagers reportedly are exploited in
prostitution.

The Government of Finland fully complies with the minimum
standards for the elimination of trafficking. The government
increased the number of trafficking cases investigated under
Finland’s trafficking statute. The Finnish national rapporteur
published her first report, an exemplary and comprehensive
critical assessment that offered the government concrete
guidance on improving its counter-trafficking policies. Although
some continued to report that the government required excessive
evidence for victim certification, thereby obstructing victim care
and prosecutions, the government increased the number of
trafficking victims identified during the year. It also cared for
trafficking victims in mixed-use shelters, which put trafficking
victims at risk of being re-victimized. In the coming year, the
government should continue to dedicate efforts to identify more
victims of trafficking, and investigate and prosecute more cases
under the trafficking statute.

For full report click here

____________________________________________________

US State Dept Terrorism Report 2009

Information sharing between Finnish and U.S. authorities
regarding terrorism-connected cases was an effective tool for
both countries. Relevant Finnish agencies monitored potential
threats closely and kept their international partners apprised of
threats with connections outside the borders of Finland.

In a rare publicized case in November, a Finnish citizen was
deported from Sweden to Finland because of suspected links to a
terrorist organization. Media reports confirmed by the government
indicated that this individual was closely monitored by the Security
Police (SUPO) after his return from Sweden.

Finland took additional steps to verify the identity of those seeking
to enter the country and anticipated a further surge in immigration
through family reunification. The Government of Finland
continued to exert significant efforts to assimilate newcomers into
society and to avoid conditions that would lead to radicalization of
minority groups. These measures included social benefits, Finnish
language training, and ombudsmen’s offices to advocate on
behalf of immigrants.

One new measure that Finland was considering to prevent the
infiltration of terrorists or their facilitators into the country was the
permanent stationing of SUPO officers at Finnish embassies
abroad. If approved, this would be the first foreign deployment of
dedicated counterterrorism personnel. The director of SUPO has
publicly stated that these officers would be focused on “stop(ping)
potential terrorists in the country of departure.” The government
has made a request to parliament for US$ 2.3 million to fund the
15-20 personnel who would be involved in the effort.

Finland continued its contributions towards building
counterterrorism capacity with overseas partners. It made
donations, under its G8 Global Partnership pledge, of
approximately US$ 14 to 21 million for the period 2004-2014,
including about US$ 350,000 as part of the Nuclear Smuggling
Outreach Initiative to provide equipment to the Kyrgyz Republic
needed to prevent the smuggling of nuclear materials that might
be sought by terrorist groups. Finland also began a police-
prosecutor training program in Afghanistan to facilitate
investigation and prosecution of serious crimes there, including
those related to terrorism, and it continued to be the third-largest
contributor of trainers to the EUPOL training program for Afghan
police. On January 22, the government reached a decision to
temporarily increase the strength of Finnish military crisis
management personnel by approximately 50 soldiers from the
current ceiling of 145, all expected to be deployed by the
beginning of 2011. Finland also aimed to allocate a larger
proportion of its development cooperation funding to the northern
provinces of Afghanistan, and to deepen its participation in the
EU police mission in northern Afghanistan.

____________________________________________________

Links:

Worldwide AML Legislation (International Bar Association)

National Bureau of Investigation / Financial Intelligence Unit
Tables & Rankings
Are there Sanctions in force against it? (UN/EU/US)
N
?
Is it on FATF list of non-cooperative countries?
N
?
Is it on OECD list of uncooperative Tax Havens?
N
?
OECD - Implementation status of Tax Standard
White
?
Is it on EU 'white' list of equivalent jurisdictions?
EU
?
Offshore Finance Center (Original IMF List)?
N
?
Is it on the US Secretary of Treasury list of jurisdictions of
Primary Money Laundering concern?
N
?
Is it on the US Secretary of State list of jurisdictions
identified to be supporters of International Terrorism?
N
?
Is it on US Department of State International Narcotics
Control Majors List?
N
?
US Dept of State Money Laundering assessment (INCSR)
M
?
Government Actions (For further info see INCRS below):
 
?
-  Criminalized Drug Money Laundering?
Y
 
-  Criminalized Beyond Drugs?
Y
 
-  Record Large Transactions?
Y
 
-  Maintain Records Over Time?
Y
 
-  Report Suspicious Transactions?(NMP)?
Y
 
-  Egmont Financial Intelligence Units?
Y
 
-  System for Identifying/Forfeiting Assets?
Y
 
-  Arrangements for Asset Sharing?
Y
 
-  Cooperates with International Law Enforcement?
Y
 
-  International Transportation of Currency?
Y
 
-  Ability to Freeze Terrorist Assets w/o Delay?
Y
 
-  Disclosure Protection "Safe Harbor"?
Y
 
-  Criminalized Financing of Terrorism?
Y
 
-  States Party to 1988 UN Convention?
Y
 
-  International Terrorism Financing Convention?
Y
 
 
Ranking
2011
Ranking
2010
 
Corruption (Transparency International)
2 (out of
183)
4 (out of
178)
?
Ease of doing business (World Bank)
11 (out of
183)
13 (out of
183)
?
FATF 40 + 9 recommendations
Mutual Evaluation Report: 2007
Further Tables
C
L
P
N
N/A
    C  -  Fully Compliant ,   
    L  -  Largely Compliant,    
    P  -  Partially Compliant    
    N  -  Non-Compliant
7
13
23
5
1
Legal Systems
 
1. Money Laundering Offence
P
 
14. Protection & no tipping-off
C
2. ML offence – mental element and
corporate liability
L
 
15. Internal controls,
compliance & audit
P
3. Confiscation and provisional
measures
L
 
16. DNFBP – R.13-15 & 21
P
4. Secrecy laws consistent with the
Recommendations
C
 
17. Sanctions
P
5. Customer due diligence
P
 
18. Shell banks
P
6. Politically exposed persons
N
 
19. Other forms of reporting
C
7. Correspondent banking
N
 
20. Other NFBP & secure
transaction techniques
C
8. New technologies & non
face-to-face business
P
 
21. Special attention for
higher risk countries
P
9. Third parties and introducers
N
 
22. Foreign branches &
subsidiaries
P
10. Record keeping
C
 
23. Regulation, supervision
and monitoring
P
11. Unusual transactions
P
 
24. DNFBP - regulation,
supervision and monitoring
N
12. Designated Non-Financial
Businesses and Professions – R.5,
6, 8-11
N
 
25. Guidelines & Feedback
P
13. Suspicious transaction reporting
L
     
Institutional and other
measures
 
26. The FIU
L
 
31. National co-operation
L
27. Law enforcement authorities
L
 
32. Statistics
P
28. Powers of competent authorities
C
 
33. Legal persons – beneficial
owners
P
29. Supervisors
P
 
34. Legal arrangements –
beneficial owners
N/A
30. Resources, integrity and training
P
 
 
 
International Co-operation
 
35. Conventions
P
 
38. MLA on confiscation and
freezing
L
36. Mutual legal assistance (MLA)
L
 
39. Extradition
L
37. Dual criminality
C
 
40. Other forms of
co-operation
L
Nine Special
Recommendations
 
SR.I Implement UN instruments
P
 
SR VI AML requirements for
money/value transfer services
P
SR.II Criminalise terrorist financing
L
 
SR VII Wire transfer rules
P
SR.III Freeze and confiscate terrorist
assets
P
 
SR.VIII Non profit
organisations
P
SR.IV Suspicious transaction
reporting
L
 
SR.IX Cross Border
Declaration & Disclosure
P
SR.V International co-operation
L
 
 
 
*Please note that FATF deems that a country has significant aml deficiencies if any
of the 'Core' Recommendations, R1, R5, R10, R13, SRII, or SRIV are rated either
Partially of Non-Compliant. These are marked in red.

For FATF to remove a country from the regular follow-up process, it has to be rated
Compliant or Largely Compliant in the above mentioned Core Recommendations
and the following Key Recommendations: -        

R3, R4, R23, R26, R35, R36, R40, SRI, SRIII, SRV

Please also note that any risk assessment should take into consideration all
follow-up reports.
FINLAND
KnowYourCountry
-  Know Your Customer Provisions
Y
 
-  Criminalized Tipping Off?
Y
 
-  Report Suspected Terrorist Financing?
Y
 
-  State Party to United Nations TOC?
Y
 
-  State Party to United Nations CAC?
Y
 
Local AML News / Sanctions
Tax Information
Business Information
Last Updated:   16 April 2012