Anti-money laundering and counter-terrorist financing

Sampo Group recognises that ML and TF 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 ML 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.

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, the Sampo Group companies have locally required controls and procedures in place and maintain their own supplementary 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 accountability for the AML and CTF framework and an AML and CTF compliance officer responsible for following up and reporting AML and CTF obligations. Furthermore, If has an AML and CTF Competence Group in each country with the responsibility to support the business operation and to provide a discussion forum for any AML and CTF matters. At Sampo Group, employees are offered AML and CTF training annually. The training topics include legal requirements, relevant risks, and controls, for example.

When providing insurance services, Sampo Group follows the authorities’ regulations and required due diligence measures to prevent ML and TF. For example, 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 appointed specialists are responsible for deciding whether to accept high-risk customers. Payments to countries classified by the European Union (EU) and the Financial Action Task Force (FATF) as high-risk countries with strategic AML and CTF deficiencies are stopped and monitored.

Sampo Group has reporting channels in place for suspected ML or TF incidents (e.g. activities, payments). All employees have an obligation to immediately report suspicions to their organisation’s investigation unit (or similar). All suspicious activity reports are reviewed and investigated and, if necessary, reported to applicable authorities.

Money laundering and terrorist financing suspicions*
reported to the authorities

* Suspicions related to customer transactions