Obligation to obtain information and to report

Development of the customer relationship and use of services must be monitored as part of the organisation of business risks and internal control. This entails for example the monitoring of financial services used by the customers, deposits, payment traffic, investment activities or the use of insurance services.

The obligation to obtain information means that if the supervised entity detects an unusual or suspicious transaction, it must inquire the purpose and reasons of the transaction, and based on the explanation received, decide whether a report should be filed with the Financial Intelligence Unit.

The background of a transaction must be investigated for example in the following circumstances:

  • The transaction differs from the ordinary in terms of amount or structure.
  • The transaction does not have an apparent financial purpose.
  • The transaction is in conflict with the customer's financial standing or other business activities.

The supervised entity is not liable to compensate for a financial loss potentially incurred by a customer from the investigation or interruption of a transaction or caused by the supervised entity's refusal of a transaction or filing a report with the Financial Intelligence Unit. However, relief from the compensation liability requires that the supervised entity has observed such a degree of care that may be required from it with a view to the circumstances.

If you suspect money laundering or the financing of terrorism

If you suspect money laundering or the financing of terrorism, file a report on a suspicious or unusual transaction with the Financial Intelligence Unit. The report should be made without delay so that no assets could be transferred beyond the reach of the authorities. The Financial Intelligence Unit may also be contacted by telephone or email.

A money laundering report does not constitute a report of an offence, and one can be filed without knowing the quality and identifying characteristics of the crime.

It is also possible to detect a suspicious transaction after the fact. The reporting obligation also applies to these cases, and failure to report is punishable.

The reporting of a suspicious transaction is an exception to the confidentiality of customer information. The supervised entity is not liable to compensate for a financial loss incurred by a customer for example due to the interruption or investigation of a transaction or caused reporting it to the Financial Intelligence Unit, if it has observed due care.

Prevention of terrorist financing

When suspecting terrorist financing, the supervised entity is under the same obligations as when detecting a suspicious transaction which may be related to money laundering. However, there is the difference that money laundering is concerned with a suspicion of the legality of the origin of the assets, whereas terrorist financing may also be based on legally obtained assets, for example in connection with fund raising or money remittance. In this case, the suspicion is concerned with the purpose of use of the assets.

When must a report be made?

A report must be filed with the Financial Intelligence Unit at least in the following circumstances:

  • An unusual transaction appears unusual even after the explanation requested from the customer.
  • A suspicious transaction is detected afterwards, or considerations making the transaction suspicious emerge afterwards.
  • The service provider executes a suspicious transaction since refusal from it would hinder investigation of the beneficiary or the matter.
  • The service provider refuses an unusual or suspicious transaction.

A money laundering report online

Suspected money laundering activity can be reported electronically on the website of Financial Intelligence Unit.

The report must be made in such a way that the Financial Intelligence Unit is able assess the case.

What is the Financial Intelligence Unit?

The Financial Intelligence Unit works under the aegis of the National Bureau of Investigation. It handles incoming reports on suspected money laundering and financing of terrorism. All information will remain strictly confidential. The Financial Intelligence Unit may also conduct a pre-trial investigation or submit the matter for investigation by another police authority.