5 perspectives for seriously tackling money laundering risks
Are you confident your business is truly protected against money laundering? Many organizations diligently follow the Anti-Money Laundering Act (PTL), but often miss the bigger picture of how criminals actually operate.
In this article, with insights from experts Marie Wallin of Rätt Nu and Nils Oppelstrup of Verified, you'll learn how to address money laundering risks in a deeper and more effective way – and in doing so, fully comply with the PTL.
This article is based on a text originally published in Kreditnytt and can be read here (in swedish):
Kreditnytt 01-2025, page 18-19.
Why do many feel unsure despite complying with PTL?
Many businesses are aware of the PTL's requirements but still feel uncertain about the complete chain of money laundering risks. This often stems from a lack of clear, practical guidance on how AML work should be conducted in Sweden. As a result, even ambitious business leaders who invest time and resources in AML efforts aren't sure if their work is truly sufficient. What exactly constitutes "sufficient"? Here, we offer five perspectives.
5 perspectives for seriously tackling money laundering risks
1. Start with criminal law risks
To prevent your business from becoming part of a criminal scheme and to protect your employees from committing the crime of commercial money laundering, you need to understand the criminal law risks. Commercial money laundering, introduced in Sweden in 2014, involves acting with "reprehensible risk-taking." If your business falls short in its risk-based approach – for example, by not conducting a proper KYC assessment or failing to follow up on a suspicious transaction – it could face criminal consequences.
2. Use criminal modus operandi to identify risks in your business
Criminals are innovative and ruthless. To succeed, they often need to act with or through legitimate actors. To work effectively against money laundering, you must understand criminal modus operandi. Ask yourself the following questions:
- What do actual money laundering schemes look like from the criminals' perspective?
- Which actors do criminals need for this specific scheme?
- How could my business be exploited?
Answering these questions requires both criminal law knowledge and experience with criminal methods. You must dare to view your business from a criminal perspective to understand how it could be misused.
3. Consolidate knowledge in your general risk assessment
Once you know how your business could be exploited, the next step is to apply this knowledge in your general risk assessment according to the PTL. Ensure it reflects the external threats and internal vulnerabilities specific to your operations. A qualitative and relevant risk assessment is the foundation for high-quality and cost-effective AML work. It's no coincidence that most sanction fees point to deficiencies in the general risk assessment – it's the hub of all risk management. A risk-based approach doesn't mean all services are handled the same way, but rather that you adapt measures based on risk.
4. Leverage technology where possible – focus on key decisions
Many businesses handle thousands of customers and transactions. To maintain consistent high quality, good technological support is crucial. While some steps cannot or should not be automated, such as obtaining updated KYC information or approving high-risk customer relationships, a comprehensive AML tech solution can significantly ease the workload and free up time for the most critical decisions. Consider the user experience when choosing a technology provider.
5. Collaborate with partners who complement you
Effectively combating money laundering requires specialized expertise that might be unreasonable for a small or medium-sized company to hire in-house. External help is available. Map out your strengths and vulnerabilities to understand your need for external expertise. Choose partners who can offer sustained support year after year and who complement your business. Integrity, drive, and a commitment to combating crime are key qualities in your employees and partners.
By working together, we can effectively counteract money laundering and financial crime.
Would you like to learn more about how to strengthen your business's defenses against money laundering and financial crime?
Contact us here.
