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. Robust and well-resourced operations to counter money laundering and terrorist financing are critical factors in Sampo Group’s success.
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.
The Sampo Group Code of Conduct and the Sampo Group Guideline for Required Internal Procedures to Prevent Money Laundering and Terrorist Financing set out the principles for AML and CTF efforts. Sampo Group is committed to having sufficient controls, procedures, and training in place to prevent the use of its products and services for money laundering and terrorist financing purposes. 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 and updated regularly to ensure accuracy of data and appropriate record-keeping. In addition, appointed specialists assess high-risk decisions and business relationships separately.
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 intended to, among other things, prevent money laundering, terrorist financing, and financial crimes.
Group goals and ambitions
Sampo Group has zero tolerance towards money laundering and terrorist financing, and it expects its employees, customers, suppliers, and other business partners to share the same view.
Money laundering and terrorist financing suspicions* reported to the authorities
*suspicions related to customer transactions
Anti-money laundering and counter-terrorist financing in Group companies
If has an Anti-Money Laundering and Counter-Terrorist Financing Policy, which establishes If’s general framework against money laundering and terrorist financing, and forms part of If’s Risk Management System. The policy is supplemented by instructions and guidelines that provide more details and specify the legal requirements set by each operating country.
If has risk-based KYC procedures in place, including identification and verification of customers. In addition, If’s customer databases undergo screening to identify politically exposed persons, in accordance with national legislation. Identified politically exposed persons are assessed by authorised decision-makers, and all decisions are stored. Payments to countries that are under increased monitoring by the Financial Action Task Force (FATF) are automatically stopped and controlled. Furthermore, payments to countries on which restrictive measures are imposed by the EU (and in some cases by the UN) regarding asset freezes and prohibitions on making funds available are also stopped and controlled.
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, consisting of appointed Business Area and Claims coordinators and representatives from Legal, Compliance, and Internal Investigations. The competence groups are responsible for performing a yearly risk assessment and considering ML/TF risk factors for the company.
If’s AML and CTF risk assessments are updated annually in accordance with local legal requirements.
Training in AML and CTF is included in If’s mandatory annual One Responsible If learning programme for all employees. In addition, targeted employees are required to undergo supplementary training.
If has reporting channels in place on the intranet both for suspected money laundering or terrorist financing and for reporting of internal irregularities. All employees have an obligation to immediately report suspected money laundering or terrorist financing to If’s Investigation unit. The Investigation unit reviews and investigates the reports and, if necessary, reports any suspicions to the authorities. Ongoing AML and CTF activities and any suspicions or reports of money laundering incidents are reported to the company management.
Topdanmark complies with laws and regulations on AML and CTF, including the UN and EU regulations on increased risk and financial sanctions. Legislation on money laundering and terrorist financing in Denmark only applies to life insurance business and does not include Topdanmark’s non-life insurance business.
Hastings has a risk-based approach towards assessing and managing the money laundering and terrorist financing risks it faces, with details set out in the related Anti-Money Laundering and Counter Terrorist Financing Policy. This policy considers all relevant laws and statutes and sets out the company’s controls and reporting framework, which monitor adherence and facilitate the reporting of breaches. Key risks in relation to financial crime, controls, any breaches, suspicious transaction reports, and audit findings are reported to the company board on an annual basis by Hastings’ Money Laundering Reporting Officer.
All employees are informed of any policy revisions through Hastings’ intranet, with mandatory training on this subject delivered and monitored through the company’s e-learning platform. Mandatory training is undertaken by all employees on an annual basis.
Any suspicions of money laundering, terrorist financing, or other associated suspicious activity can be reported anonymously via Hastings’ whistleblowing platform or via a dedicated restricted-access mailbox for investigation by the second line of defence. All suspicious activity reports are responded to within 48 working hours of the notification being received, with an outcome reached within 10 working days.
Hastings conducts sanctions screening and reports, as necessary, to the relevant authorities. Any incidents or events connected to money laundering, terrorist financing, or sanctions are also reported to the appropriate management and governing body forums.
Mandatum evaluates money laundering and terrorist financing risks at least annually, considering the risks relating to customers, countries and geographical areas, products, services, transactions, technologies, and distribution channels. Mandatum considers its investment and savings products to have a normal risk of money laundering and terrorist financing, whereas the risk for pension products and life insurance products is regarded as low.
Mandatum uses a risk-based approach to classify customers in different risk categories, and it applies enhanced due diligence measures for customers presenting a higher risk, such as politically exposed persons or customers with ties to high-risk jurisdictions. Derived from the risk-based approach, each Mandatum Group company has implemented an Anti-Money Laundering and Counter-Terrorist Financing Policy, which sets out the requirements for complying with relevant AML and CTF laws and regulations. The policies are supplemented with guidelines and instructions to specify procedures in the different business areas.
The main forum for AML and CTF matters at Mandatum is the AML Steering Group, which is headed by Mandatum’s AML directors and AML officers and has representatives from the Legal, Compliance, Client Service, IT, and Back Office functions. The AML Steering Group is an expert group providing support to Mandatum’s AML directors, who have overall responsibility for AML and CTF matters at Mandatum Group. The Board of Directors of each Mandatum Group company reviews and approves the AML policies and the business-wide risk assessments at least annually. Mandatum’s business units are responsible for the implementation of the policies and necessary procedures, with support from the AML officers.
Mandatum’s employees are required to participate in annual AML and CTF training, in accordance with their work profiles. The company organises additional training when legislative changes or procedural changes occur. New employees are introduced to Mandatum’s AML and CTF procedures and internal guidelines during the onboarding programme.
Mandatum has procedures in place for ongoing monitoring of suspicious transactions and activities. The AML officers are responsible for investigating internally reported cases and making a final decision on reporting the cases to the authorities.
Sampo plc’s CEO, together with the Compliance organisation, ensures that sufficient resources are allocated to the prevention of money laundering and terrorist financing at Sampo plc. Sampo plc is also in charge of the annual review and update of the Sampo Group Code of Conduct, which includes group level guidelines on anti-money laundering and terrorist financing.
All Sampo plc’s employees are required to familiarise themselves with the Sampo Group Code of Conduct upon employment, and after that to take part in an internal training every other year.