The Swedish Financial Intelligence Unit’s 2024 Annual Report – what does it mean for obliged entities?

The Swedish Financial Intelligence Unit (Finanspolisen) reports that Sweden has continued to strengthen its efforts to combat money laundering and terrorist financing in 2024. What practical lessons should obliged entities take from the report?

Reporting quality matters more than ever

In 2024, the Swedish Financial Intelligence Unit received over 61,000 suspicious transaction reports (STRs) – a 9% increase on the previous year. At the same time, nearly 500 reports were rejected due to incomplete information, a sharp decrease compared with the previous year. Common shortcomings include:

• Missing counterparty details.
• No suspicion hypothesis or risk indicators.
• Unclear or missing account balances (which will become mandatory to include from summer 2025).

Ensure internal procedures lead to complete, well-structured submissions. This improves quality – and increases the likelihood that reports result in concrete action. The strongest reports are those that require no follow-up questions from the Swedish Financial Intelligence Unit.

Companies are used as tools for crime – but remain underreported

The Swedish Financial Intelligence Unit notes that companies play a central role in money laundering, including within networked environments. Yet transactions between companies (B2B) account for less than 5% of all reported transactions; reports frequently target private individuals instead.

Obliged entities should be especially alert to unusual business relationships or high turnover without a clear commercial rationale. The use of corporate structures as laundering tools is a growing challenge; greater focus by obliged entities would strengthen regulatory compliance. Where proportionate, consider whether operating models such as outsourced aml compliance could enhance monitoring capacity and coverage.

New tools to freeze and confiscate assets

In 2024, new legislation on non-conviction-based confiscation entered into force, enabling seizure of assets even when they are not directly linked to a specific offence. The Swedish Financial Intelligence Unit issued 78 decisions imposing a prohibition on disposal – a tool to temporarily freeze assets.

When reporting transactions that indicate preparations to conceal assets, specify whether there are circumstances that could justify a prohibition on disposal.

Collaboration to counter money laundering

The Swedish Financial Intelligence Unit is deepening collaboration with banks, supervisory authorities and other FIUs, both nationally and internationally. Within Samlit and other forums, vulnerabilities in specific sectors – for example, non-profit associations and wholesale trading companies – are analysed.

There are several relevant networks and a steady flow of updates. Stay informed about the work of the national co-ordination function, for example by following “Spot on!” via its LinkedIn page.

Reporting is not just a duty – it is a protection

According to the Swedish Financial Intelligence Unit, obliged entities stopped close to 3,000 suspicious transactions in 2024 before execution.

When transactions linked to fraud, criminal proceeds or money laundering are identified and halted early, it is not only the reporting that matters. Taking proactive measures protects society and reduces the obliged entity’s own risks.

How our AML compliance consulting helps

Morling Consulting supports obliged entities in meeting AML requirements across Europe. We offer:

• Reviews of internal processes.
• Bespoke AML training.
• Horizon scanning based on current risk reports and legislation, among other sources.

Do you want to ensure your procedures meet applicable requirements? Contact one of our experienced AML lawyers for an initial discussion. We also provide outsourced aml compliance arrangements where appropriate.