Money laundering is defined as the process where the identity of the proceeds of crime are so disguised that it gives the appearance of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firm's knowledge or suspicions.

Globally, in revenue terms, the amount of money laundered would make it the world’s third largest industry.

In common with many other countries, Sweden has passed legislation designed to prevent money laundering and to combat terrorism. This legislation, together with regulations, rules and industry guidance, forms the cornerstone of AML/CTF obligations for Swedish firms and outlines the offences and penalties for failing to comply.

Whilst are currently unregulated and do not fall with the scope of the AML/CTF obligations in Sweden the senior management has implemented systems and procedures that meet Swedish AML legislation. This decision reflects the senior management’s desire to prevent money laundering and not be used by criminals to launder proceeds of crime.


The Swedish AML regime is set out in the following legislation and regulations:

  • SFS 2009:62 Act on Measures against Money Laundering and Terrorist Financing

The ANTI-MONEY LAUNDERING Policy is designed to prevent money laundering by meeting Swedish AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This ANTI-MONEY LAUNDERING Policy sets out the minimum standards which must be complied with and includes:

  • The appointment of a Money Laundering Reporting Officer (MLRO) who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;
  • Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;
  • Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);
  • Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
  • Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
  • The maintenance of appropriate records for the minimum prescribed periods;
  • Training and awareness for all relevant employees
SANCTIONS POLICY: is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.