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Anti-Money Laundering and Counter-Terrorist Financing

Sampo Group has zero tolerance toward money laundering and terrorist financing, and it expects its employees, customers, suppliers, and other business partners to share the same view.

Sampo Group recognizes that money laundering and financing of terrorism are serious problems for society in general. Money laundering and terrorist financing are illegal, and financial services companies tend to be favored channels through which illicit money is laundered. Robust and well-resourced operations to counter money laundering and terrorist financing are critical factors in the Group companies’ success.

For Sampo Group, the risk of AML and CTF is considered low overall, but more significant in life insurance companies than in non-life insurance operations. 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.

Sampo Group companies are committed to complying with the applicable national AML and CTF rules and legislation. 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. The 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. Customer databases are screened and updated regularly to ensure accuracy of data and appropriate record-keeping. High-risk decisions and business relationships are assessed separately by appointed specialists.

The managing director of each company in Sampo Group has the 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 necessary and appropriate measures to comply with the applicable local rules and various sanctions regimes, which may be imposed by the UN and/or the EU. Reporting on AML and CTF 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. Sampo plc’s Compliance organization is responsible for organizing the reporting to Sampo plc’s Audit Committee and Board of Directors. In some countries, Sampo Group companies 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.

Every year, Sampo Group companies report some suspicions of money-laundering or terrorist financing to the authorities. This was the case also in 2020. The reporting shows that the internal guidelines and procedures for identifying and following up on unusual or suspicious activities work. In addition, Sampo Group companies have internal reporting channels available for reporting irregularities. During 2020, no irregularities were reported.

AML and CTF Irregularities Reported Internally, Sampo Group 2020 2019 2018
If 0 0 0
Topdanmark 0 0 0
Mandatum Life 0 0 0
Sampo plc 0 0 0
Sampo Group* 0 0 0

*excluding Hastings


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. Further, If has risk-based procedures in place for identification, verification, and KYC procedures. If’s customer databases undergo AML screening six days a week in accordance with national legislation. All hits on PEP or sanction lists are assessed by authorized decision makers and all decisions are stored. Countries imposed with restricted measures, sanctions adopted by the EU or UN and high-risk jurisdictions with strategic deficiencies by EU and FATF undergo enhanced due diligence. All transactions to countries on these lists and jurisdictions with strategic deficiencies by EU and FATF are automatically stopped and assessed manually by authorized decision makers before approval.  

If has appointed a board member with overall responsibility for coordinating the AML and CTF framework within If, and an AML officer responsible for controlling and reporting obligations. There are further coordinators in each Nordic country, who work closely with the local AML and CTF competence groups. The competence groups consist of employees representing the different parts of the organization: business areas, Legal, Compliance, and Internal Investigations in each country. Coordinators are, with support from the competence groups, responsible for performing a yearly risk assessment and considering risk factors for the company.

To support employees regarding AML and CTF matters, If has e-learning programs on risk-based AML and CTF. The e-learning programs are mandatory for all employees working with products covered by AML legislation in the Sales and Claims units. AML and CTF training is also part of the regular policy certification processes and the yearly training for employees working with insurance distribution. 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, the AML officer reports any suspicions to the authorities. Ongoing AML and CTF activities and any suspicions of or reported money laundering incidents are reported to the company management.

General AML and CTF risk assessments are updated annually in accordance with legal requirements, and they are documented in all If countries covered by the AML legislation.


In general, Topdanmark considers the risk of money laundering and terrorist financing to be low. This is supported by an assessment made by the Danish Financial Supervisory Authority (FSA) on the general risk of money laundering and terrorist financing in the pensions industry in Denmark, which was found to be low.

Legislation on money laundering and terrorist financing only applies to Topdanmark’s life insurance business and does not include Topdanmark’s non-life insurance business. Topdanmark Life Insurance has implemented an Anti-Money Laundering Policy and Procedure Framework designed to comply with AML laws and regulations throughout the company. These include counter-terrorist financing. The AML officer is responsible for compliance with relevant legislation and industry standards. The AML officer is also responsible for monitoring AML and CTF activities and providing the Executive Board with reports on risks, implemented measures, and internal controls on a quarterly basis. The AML officer works in cooperation with Internal Audit.

Topdanmark uses an overall risk assessment when reviewing risks related to money laundering and terrorist financing. The assessment takes into account risk factors that include those relating to customers, geographic areas, products, transactions, and delivery channels. The risk assessment is reviewed regularly.

Further, Topdanmark has risk-based procedures for identification, verification, and KYC procedures, including enhanced due diligence for those customers presenting higher risk, and identification of beneficial owners. In addition, all customers are categorized in accordance with their risk potential regarding money laundering and terrorist financing. The company also has a process for identification of politically exposed persons, as well as internal procedures for observing suspicious transactions, and activities to ensure that the procedures are complied with in practice.

In accordance with the Danish Anti-Money Laundering Regulation, Topdanmark has an obligation and processes in place to notify the Danish authorities of any suspicions of money laundering or terrorist financing. Topdanmark’s Compliance Office controls and assesses whether the company’s internal procedures are efficient, and if there is sufficient reporting to the authorities.

For employees, Topdanmark provides an e-learning program on risk-based AML. The e-learning program is mandatory for all new employees within the first month of employment at Topdanmark Life Insurance, and every second year for employees handling life insurance products at Topdanmark Insurance.


Hastings Group’s (Hastings) Anti-Money Laundering and Counter Terrorist Financing Policy sets out the Hastings’ risk-based approach towards assessing and managing the money laundering and terrorist financing risks it faces, considering all relevant laws and statutes. The policy also sets out the controls and reporting framework which monitor adherence and facilitate the reporting of breaches.

Employees are informed via the intranet when the policy has been revised and they are required to undertake regular mandatory training via e-learning modules.

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 defense. All Suspicious Activity Reports are reviewed and investigated within 48 working hours of the notification being received, with an outcome reached within 10 working days.

Hastings conducts appropriate sanctions screening and reports, as necessary, to relevant authorities; any incidents or events connected to money laundering or terrorist financing are also reported to appropriate management and governing body forums.

Mandatum Life

Mandatum Life evaluates money laundering and terrorist financing risks annually, considering the risks relating to customers, geographic areas, products, transactions, and delivery channels. Mandatum Life considers its investment 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 Life uses the risk-based approach to classify customers in different risk categories and applies enhanced due diligence measures for customers presenting a higher risk, such as politically exposed persons or customers with ties to high-risk jurisdictions. Mandatum Life also has procedures in place for ongoing monitoring of suspicious transactions. The AML officer and local contact persons are responsible for investigating internally reported cases and making a final decision on reporting the cases to the authorities.

Based on this risk-based approach, Mandatum Life 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 policy is supplemented with guidelines and instructions to specify procedures in the different business areas.

The main forum for AML and CTF matters in Mandatum Life is the AML Steering Group, which is headed by the AML officer and has representatives from the Legal, Client Service, IT, and Back Office functions. The AML Steering Group is an expert group providing advice to Mandatum Life’s director responsible for Client Service, Baltics, and IT, who has overall responsibility for AML and CTF matters in the company. The Board of Directors reviews and approves the policy and risk assessment annually. Mandatum Life’s business units are responsible for the implementation of the policy and necessary procedures, with support from the AML officer and contact persons.

Mandatum Life employees are required to participate in Mandatum Life’s annual AML and CTF training, in accordance with their work profiles. Additional training is organized when legislative changes or procedural changes occur. New employees are introduced to Mandatum Life’s AML and CTF procedures and internal guidelines during the onboarding program.

More information in Sampo Group’s Corporate Responsibility report, p. 30.

Updated 16 Aug 2021