Supervision release 2 November 2023 – 60/2023

Revision of EBA ML/TF Risk Factors Guidelines into force on 3 November 2023

On 31 March 2023, the European Banking Authority (EBA) issued Guidelines (EBA/GL/2023/03) revising EBA Guidelines EBA/2021/02 (EBA ML/TF Risk Factors Guidelines).

The FIN-FSA has announced to the EBA it will comply with the Guidelines.

In accordance with Article 16(3) of the EBA Regulation1, credit and financial institutions must make every effort to comply with EBA guidelines.


The purpose of the Guidelines is to complement the EBA ML/TF Risk Factors Guidelines. The Guidelines provide more detailed guidance regarding customers that are not-for-profit organisations (NPOs).

Entry into force

The Guidelines apply as of 3 November 2023.

For further information, please contact

Jonna Ekström, Chief Legal Counsel, telephone +358 9 183 5531 or jonna.ekstrom(at)


EBA Guidelines amending Guidelines EBA/2021/02 on customer due diligence and the factors credit and financial institutions should consider when assessing the money laundering and terrorist financing risk associated with individual business relationships and occasional transactions under Articles 17 and 18(4) of Directive (EU) 2015/849

1Regulation (EU) N:o 1093/2010.