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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 the Group companies’ success.

For Sampo Group, the risk of money-laundering and terrorist financing is considered low overall. 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.

Group-level approach

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 group-level principles for AML and CTF efforts. The Group companies are committed to having sufficient controls, procedures, and training in place to prevent the use of the Group companies’ services and products for money laundering and terrorist financing purposes. When providing insurance services, the Group companies 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 organises 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 organised 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 organisation is informed of all relevant incidents. Sampo plc’s Compliance organisation is responsible for organising the reporting to Sampo plc’s Audit Committee and Board of Directors.

In some countries, the 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.


Money laundering and terrorist financing suspicions* reported to the authorities, Sampo Group 2021 2020 2019
If 248 222 225
Topdanmark 3 8 7
Hastings 0 - -
Mandatum 3 6 2
Sampo plc 0 0 0
Sampo Group 254 236 234

*suspicions related to customer transactions



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.

Furthermore, 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 identified politically exposed persons or sanction lists are assessed by authorised decision-makers, and all decisions are stored. Countries on which restricted measures, or sanctions adopted by the EU or UN, are imposed, and high-risk jurisdictions with strategic deficiencies identified by the EU and Financial Action Task Force (FATF), undergo enhanced due diligence. All transactions to countries on these lists and jurisdictions with strategic deficiencies identified by the EU and FATF are automatically stopped and assessed manually by authorised 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 organisation: Business Areas, Legal, Compliance, and Internal Investigations in each country. The coordinators are, with support from the competence groups, responsible for performing a yearly risk assessment and considering risk factors for the company.

If updates general AML and CTF risk assessments annually, in accordance with legal requirements, and documents them in all If countries covered by the AML legislation.

Employee training

To support employees in AML and CTF matters, If has e-learning programmes on risk-based AML and CTF. The e-learning programmes 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.

Incident reporting

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.



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, geographical areas, products, transactions, and delivery channels. The risk assessment is reviewed annually, or when significant changes occur.

Furthermore, 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 categorised 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 general, Topdanmark considers the risk of money laundering to be low and the risk of terrorist financing to be very 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.

Employee training

For employees, Topdanmark provides an e-learning programme on risk-based AML. The e-learning programme 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.

Incident reporting

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.



Hastings’ Anti-Money Laundering and Counter Terrorist Financing Policy sets out the company’s 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 that monitor adherence and facilitate the reporting of breaches. Hastings’ money laundering reporting officers report annually to the company Board on key risks in relation to financial crime, controls, any breaches, suspicious transaction reports, and audit findings.

Employee training

Hastings employees are informed via the intranet when the Anti-Money Laundering and Counter Terrorist Financing Policy has been revised. All employees are required to undertake mandatory training modules on an annual basis, and these are delivered and monitored via the company’s e-learning platform.

Incident reporting

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 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 evaluates money laundering and terrorist financing risks annually, considering the risks relating to customers, geographical areas, products, transactions, and delivery channels. Mandatum 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 uses a 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.

Based on 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 in Mandatum is the AML Steering Group, which is headed by Mandatum Group’s AML director and AML officer 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 director, who has overall responsibility for AML and CTF matters in Mandatum Group. The Board of Directors of each Mandatum Group company reviews and approves the AML policies and risk assessments annually. Mandatum’s business units are responsible for the implementation of the policies and necessary procedures, with support from the AML officer and contact persons.

Employee training

Mandatum’s employees are required to participate in annual AML and CTF training, in accordance with their work profiles. Additional training is organised 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.

Incident reporting

Mandatum 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. The reporting is done by email.

Sampo plc

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. The employees of Sampo plc are required to familiarise themselves with the Sampo Group Code of Conduct, which includes AML and CTF, every other year.

More information in Sampo Group’s Sustainability Report.

Updated 25 Apr 2022