Finansinspektionen’s 2025 focus areas for preventing money laundering and more

This blog post addresses the Swedish Financial Supervisory Authority’s (Finansinspektionen, FI) focus areas for 2025. For an overview of FI’s supervisory priorities for 2026, see our post on Finansinspektionen’s 2026 Supervisory Priorities.

Money laundering, terrorist financing and the evasion of sanctions continue to pose significant threats to both European and global financial systems. The Swedish Financial Supervisory Authority (Finansinspektionen, FI) has now communicated the areas it will prioritise in 2025 to counter money laundering and related criminal activity. The full FI report is available.

Areas of highest risk in 2025

Client money accounts

These accounts are misused for money laundering because they increase anonymity in transactions. FI and the Financial Action Task Force (FATF) note that client money accounts can be used to conceal or integrate criminal proceeds—for example by channelling funds into property or securities.

Banks and other firms that provide accounts for the administration of client funds should review their management of client money accounts as part of a risk based approach AML and anti money laundering consulting framework.

Correspondent relationships and correspondent banking due diligence

Correspondent relationships are used to offer financial services in other jurisdictions and to execute cross-border payments. These relationships require banks to rely on counterparties’ compliance, creating elevated risks where controls are weak.

Banks with international relationships or cross-border payment operations should reassess their correspondent banking due diligence and monitoring arrangements, supported where appropriate by AML risk assessment and AML gap analysis.

Companies as criminal tools

Companies may be used to obscure beneficial owners, execute large transactions or introduce cash into the banking system. FI observes that legal persons are frequently used in more advanced laundering schemes—a logical development given that companies can make large and complex transactions appear legitimate in ways that private individuals cannot.

All financial firms with corporate clients—especially those handling substantial cash flows or complex ownership structures—must ensure effective controls for anti money laundering consulting practices, including robust beneficial ownership verification and AML/CFT risk assessment.

Digital banking services and crypto-assets

Technological development in financial services is rapid. In parallel, risks increase that criminals exploit weak controls, particularly in crypto-markets. FI specifically warns about providers offering crypto-services without registration—often with low risk awareness.

Fintechs, digital banks, crypto-brokers and other digital payment service providers should review their compliance against AML/CFT requirements, including independent AML gap analysis and, where needed, AML compliance outsourcing.

Smaller and mid-sized banks

As major banks have improved their frameworks, criminals increasingly seek out smaller institutions that offer similar services but may lack the capacity for advanced screening and monitoring. Regional and niche banks should remain alert to whether this trend leads to an adverse selection of customers.

Targeted AML risk assessment, reinforced first- and second-line controls and, where appropriate, specialised AML compliance consulting can mitigate these exposures.

Terrorist financing

Terrorist financing can involve small sums and both lawful and unlawful sources. Transfers can be rapid and anonymous, placing high demands on all actors that handle payments and cross-border transfers. With the threat level assessed as high, financial firms face stringent compliance expectations.

Banks, payment service providers and crypto-market actors should test and evidence the effectiveness of their measures against terrorist financing, leveraging AML/CFT risk assessment and clear escalation thresholds.

International sanctions

Following Russia’s invasion of Ukraine, sanctions frameworks have tightened. In an in-depth 2024 analysis, FI concluded that many banks’ sanctions screening accuracy can be improved and that controls should be strengthened to prevent sanctions breaches. All financial firms offering services or products that involve the handling of economic resources—particularly banks—should review the effectiveness of their work on sanctions compliance.

Enhancements may include a sanctions compliance program, improved data quality and model governance, and documented end-to-end testing.

Inter-agency cooperation and FI’s supervision

FI’s work is grounded in a risk-based approach and conducted in cooperation with other authorities, in Europe and internationally. Collaboration with the Swedish Financial Intelligence Unit (Finanspolisen), the Swedish Economic Crime Authority (Ekobrottsmyndigheten) and the European Banking Authority (EBA) supports a broader understanding of risk and more effective supervision.

What do these risk areas mean for your business?

For financial firms, it is essential to understand how these risks may affect your business. Failures in AML/CFT may have legal and commercial consequences, including reduced trust among customers and other stakeholders.

At Morling Consulting, we help financial firms identify and manage these risks in practice—with measures that work in the real world. Our services span AML risk assessment, AML/CFT risk assessment, AML gap analysis, correspondent banking due diligence, beneficial ownership verification and AML compliance outsourcing across Europe. Want to know how we can support your operations? Get in touch.