Anti-money laundering and counter-terrorist financing

Sampo Group recognises that money laundering and terrorist financing are serious problems for society in general, and financial services companies tend to be favoured channels through which illicit money is laundered. A defence 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. For an insurance company, being able to evaluate risks is at the core of business. For Sampo Group, the risk of money-laundering and terrorist financing is considered low overall.

Governance

The Sampo Group Code of Conduct and the Sampo Group Guideline for Required Internal Procedures to Prevent Money Laundering and Terrorist Financing outline the group level principles for anti-money laundering and counter-terrorist financing (AML and CTF) efforts. In addition, Sampo Group has locally required controls and procedures in place and each Sampo Group company maintains its own AML and CTF policies and guidelines tailored to its specific operations. Each Group company also has its own governance structure for managing AML and CTF related work. For example, If has appointed a board member with overall responsibility for coordinating the AML and CTF framework and an AML/CTF compliance officer responsible for controlling and reporting obligations. Furthermore, there are AML/CTF competence groups in each country. At Sampo Group, employees are offered both mandatory and voluntary training annually to prevent the use of the company’s products and services for money laundering and terrorist financing purposes, and targeted employees are required to undergo supplementary training.

When providing insurance services, Sampo Group follows the authorities’ regulations and required due diligence to prevent money laundering and terrorist financing. Customer databases are screened to identify politically exposed persons and updated regularly to ensure accuracy of data and appropriate record-keeping. In addition, Sampo Group’s appointed specialists assess high-risk decisions and business relationships separately. Payments to countries that are under increased monitoring by the Financial Action Task Force (FATF) or on which the European Union (EU) or the United Nations (UN) has imposed restrictive measures regarding asset freezes are automatically stopped and controlled.

In some countries, Sampo Group has a legal obligation to know its customers (Know Your Customers, KYC), which means that additional processes are necessary when working with customers. These obligations are based on legislation on the prevention of money laundering, terrorist financing, and financial crime.

Incident reporting

Sampo Group has reporting channels in place both for suspected money laundering or terrorist financing and for reporting of any internal irregularities. All employees have an obligation to immediately report suspected money laundering or terrorist financing to their organisation’s investigation unit. All suspicious activity reports are reviewed and investigated and, if necessary, reported to the authorities and the company’s management.