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Sampo plc and its subsidiaries are subject to stringent anti-money laundering (AML) and counter-terrorist financing (CTF) regulations, as financial service companies tend to be favored channels through which illicit money is laundered. For Sampo Group, the risk of AML and CTF is considered low overall, but more significant in life insurance than in non-life insurance. This is also reflected in legislation, as AML legislation only applies to life insurance in Sweden, Denmark, Estonia, Latvia, and Lithuania. In Norway and Finland, both life and non-life insurance are covered by the legislation. If’s branch offices in France, Germany, the Netherlands, and the UK comply with their respective national AML and CTF legislation.
A defense against money laundering is required by law, but it also goes hand in hand with the insurance business in the sense of good risk selection. As an insurance company, being able to evaluate risks is at the core of business. In order to do that, Sampo Group companies, in some countries, have a legal obligation to know their customers (Know Your Customers, KYC), which means that additional processes are necessary when working with customers. These obligations are based on legislation intended to, among other things, prevent money laundering, terrorist financing, and financial crimes.
The Sampo Group Code of Conduct and the Sampo Group Guideline for Required Internal Procedures to Prevent Money Laundering and Terrorist Financing set out group-level principles in relation to AML and CTF efforts. All Sampo Group companies comply with the applicable local AML and CTF rules and legislation. In order to meet the requirements of applicable legislation, Sampo Group companies are committed to having sufficient controls, procedures, and training in place to prevent the use of Group companies’ services and/or products for money laundering and terrorist financing purposes. When providing insurance services, Sampo Group companies always follow authority regulations and required due diligence to prevent money laundering and terrorist financing.
The managing director of each company in Sampo Group has ultimate responsibility for ensuring that sufficient resources are allocated to the prevention of money laundering and terrorist financing. Each Group company organizes the duties and takes other measures it deems necessary and appropriate to be able to comply with the applicable local rules and various sanctions regimes, which may be imposed by the United Nations and/or the European Union.
Reporting on anti-money laundering and counter-terrorist financing activities, as well as potential incidents, is organized in each Group company in a manner that ensures that the management and the boards of directors of relevant companies receive all material information without undue delay and that Sampo plc’s Compliance organization is informed of all relevant incidents in a timely manner. Sampo plc’s Compliance organization is responsible for organizing the reporting of relevant incidents to Sampo plc’s Audit Committee and Board of Directors.
|Reported AML and CTF Incidents, Sampo Group||2019|
|Number of cases reported to the authorities||Some suspicions reported to the authorities. No confirmed cases.|
|Number of incidents reported through internal reporting channels||0|
Further information can be found in the Corporate Responsibility Report (page 29).