Sanctions risk assessment updated: payment service providers have the most room for improvement in measures to comply with sanctions regulations and national freezing orders
The Financial Supervisory Authority (FIN-FSA) has published a summary of the updated sanctions risk assessment concerning the sectors supervised by the FIN-FSA under the AML Act. The previous summary of the sanctions risk assessment was published in autumn 2024. The sanctions risk assessment evaluates the policies, procedures and internal controls in place in each sector to comply with sanctions regulations and national freezing orders in relation to the sector’s risk exposure. By contrast, the sanctions risk assessment does not evaluate the risk of different sectors acting in violation of sanctions.
According to the updated risk assessment, there has been no notable change in sanctions risk exposure. Risk exposure remains elevated in sectors that offer various cross-border payment services enabling quick and easy transfers of funds from one place to another. These include, for example, credit and payment institutions providing international payment services, registered payment service providers, and crypto-asset service providers.
With regard to controls, the update paid particular attention to whether supervised entities' controls had shown positive developments – based on information reported in the annual data collection on money laundering and terrorist financing risks and controls – after the FIN-FSA's Regulations and guidelines 4/2023 Customer due diligence related to compliance with sanctions regulations and national freezing orders entered into force on 1 March 2024. Regarding controls, supervisory findings made by the FIN-FSA in 2024 and 2025 have also been taken into account.
Positive development in controls has taken place particularly in the insurance sector and among authorised fund management companies (UCITS and AIFs). By contrast, the development of controls in the payment services sector has not been sufficient given the sector's sanctions risk exposure.
The purpose of the sanctions risk assessment is to support the FIN-FSA’s risk-based supervision insofar as it concerns the supervision of compliance with the obligations set out in chapter 3, section 16 of the AML Act. Based on the results of the updated sanctions risk assessment, supervisory measures will be targeted at sectors demonstrating an insufficient level of controls relative to the risk exposure.
For further information, please contact
Pekka Vasara, Head of Division, Anti-Money Laundering, pekka.vasara(at)fiva.fi or telephone +358 9 183 5513.
Appendix
Summary of the sanctions risk assessment 2025