Swedish FIU 2025

The Swedish Financial Intelligence Unit’s 2025 annual report shows that anti-money laundering work is becoming more coordinated, more operational and more focused on the structures of the criminal economy than before. For businesses subject to anti-money laundering legislation, the report is therefore not only relevant for monitoring external developments, but also a clear indication of the risks and working methods now being prioritised. For businesses requiring support in these areas, it is particularly important to understand how an AML lawyer can help translate regulatory requirements into practical processes.

This is particularly relevant where the Swedish Financial Intelligence Unit describes how cooperation between public authorities and private-sector actors is being used more actively. The report states that, during the year, the Financial Intelligence Unit led several cooperation projects with both supervisory authorities and credit institutions under the powers set out in Chapter 4a of the Anti-Money Laundering Act. This points to a legal environment in which information sharing, supervision and operational measures are being linked more closely than before.

How an AML lawyer supports stronger cooperation and operational impact

A key observation in the annual report is that cooperation no longer appears to be a parallel track, but a core tool in anti-money laundering work. The Swedish Financial Intelligence Unit describes how complex arrangements, cross-border transactions and fragmented information mean that no single actor holds the complete picture. Cooperation with both public authorities and regulated entities has therefore gained clearer operational significance.

It is particularly notable that the report highlights cooperation with supervisory authorities such as the Swedish Inspectorate of Auditors (Revisorsinspektionen) and the County Administrative Board. According to the report, this cooperation has, among other things, concerned suspected enablers of large-scale money laundering in businesses supervised under anti-money laundering legislation, and has enabled supervisory authorities to target supervision and take measures such as sanctions or withdrawal of authorisation.

For anti-money laundering work by accounting and audit firms, this is important. It does not mean that every accounting or audit business is inherently high risk. However, the report shows that sectors outside the traditional financial sector may increasingly be used as potential enablers and may therefore become a focus for supervisory activity.

Companies used as criminal tools are high on the agenda

The annual report makes clear that, in recent years, the Swedish Financial Intelligence Unit has prioritised work against large-scale money laundering through companies. In 2025, this was also the theme of several cooperation projects, and four thematic analyses focusing on companies used as criminal tools were carried out within the strategic cooperation with banks.

The report estimates that the proportion of suspicious activity reports involving suspected use of companies was approximately 15 per cent in 2025. At the same time, the Swedish Financial Intelligence Unit emphasises that there remains a significant dark figure regarding arrangements where corporate accounts are used for money laundering. This is an important signal. The focus is therefore not only on cash-intensive arrangements or transactions by private individuals, but on companies, corporate accounts, identities, creditworthiness and established business structures exploited for criminal purposes.

The report also provides a concrete example: active companies with established bank accounts and creditworthiness are suspected of having been acquired for use as money laundering tools, after which funds were layered through several companies and then transferred abroad. As a result of cooperation, credit institutions closed accounts and terminated customer relationships.

For businesses working closely with corporate structures, beneficial owners, ongoing bookkeeping and corporate changes, this means that customer due diligence must be more than a formality. It is rarely sufficient to verify identity at onboarding. The risk profile may change when owners are replaced, transaction patterns shift or the company’s business rationale no longer matches its actual operations.

Almost all reporting comes from financial services and gambling operations

An interesting part of the report is how clearly reporting continues to be dominated by financial services. The chart on reporting categories shows that 69 per cent of suspicious activity reporting came from banking and financing activities, 23 per cent from the wider financial sector and 6 per cent from gambling operations. This means that around 98 per cent of reporting came from financial services and gambling operations, while the remaining non-financial sector accounted for 1 per cent and public authorities for 1 per cent.

This can be contrasted with the statistical appendix, where the accounting or audit services category is reported as having submitted 139 suspicious activity reports in 2025, while financial services and gambling operations reported many times more during the year.

It would be simplistic to conclude that accounting and audit-related businesses therefore have no significance in anti-money laundering work. The financial sector naturally handles large transaction volumes and has different system capabilities for monitoring and reporting. However, the contrast is still so significant that it raises a practical compliance question: does the low level of reporting from accounting and audit-related businesses reflect a genuinely low detection rate of suspicions, or does it indicate that risk indicators, control methods and reporting procedures are not yet sufficiently mature in these businesses?

This is precisely where anti-money laundering work by accounting firms becomes particularly relevant. When the Swedish Financial Intelligence Unit also points to companies as criminal tools, and when cooperation with supervisory authorities is intensifying, it becomes harder to view the accounting sector as a peripheral actor in the practical application of the regulatory framework.

Increased registration outside the financial sector changes expectations

The annual report also shows that the number of registered regulated entities increased clearly in 2025, particularly in sectors outside the financial sector. Law firms are specifically highlighted, but the report also notes marked increases among independent legal professionals, bookkeeping services and tax advisory services.

This is significant for two reasons. First, it shows that more actors in these sectors are now included in the goAML reporting system, which improves the conditions for information exchange and rapid reporting. Secondly, it is likely to mean that expectations regarding actual reporting capability will increase. A business that is registered, supervised and handles money laundering risks related to companies must be able to demonstrate how it works with risk assessment, customer due diligence, escalation and reporting in practice.

An AML lawyer’s role as sanctions offences become part of AML work

The report also highlights money laundering linked to sanctions offences as another area in which the Swedish Financial Intelligence Unit initiated new cooperation during the year. This cooperation covers both banks and other public authorities and aims to counter money laundering in connection with transactions that may be suspected of breaching EU or UN sanctions regulations.

This perspective is important even for businesses that do not themselves handle payment flows to the same extent as banks. Accounting firms, advisers and other professional service providers may come into contact with corporate structures, payment patterns, counterparties or ownership arrangements that are also relevant to sanctions risk. This means that internal procedures must, at a minimum, be capable of detecting signals such as unusual international connections, changed ownership structures, intermediaries without a clear business function or transactions that do not correspond to the customer’s known business. It is also important to emphasise that no actor may do business with sanctioned persons, companies or, in certain cases, companies represented by sanctioned persons.

What does this mean in practice for companies outside the financial sector?

The report’s most business-relevant message is that the Swedish Financial Intelligence Unit appears to be placing greater emphasis on the full chain surrounding the criminal economy. Banks still account for the vast majority of reporting, but the authorities’ focus also includes enablers, corporate structures and sectors where control points exist earlier in the business flow.

For companies and advisory businesses outside the financial sector, this suggests that AML work should be tested against several fundamental questions:

• Does the general risk assessment capture the risk of companies being used as criminal tools?
• Is customer due diligence sufficiently dynamic to capture ownership changes, unusual behaviour and unclear business models?
• Are there documented procedures for internal escalation when suspicions arise in customer engagements?
• Can the business justify why certain situations have not resulted in reporting?
• Are employees trained to identify risk indicators in company-related arrangements, not only in pure payment flows?

It is also worth noting that, during 2025, the Swedish Financial Intelligence Unit carried out several targeted feedback initiatives on suspicious activity reporting and also emphasised deficiencies such as the absence of basic counterparty information, long response times and incomplete descriptions of suspicions. This suggests that the quality of reporting will be scrutinised more concretely, not only whether reporting takes place.

A report that should be read more widely than by financial firms

The Swedish Financial Intelligence Unit’s 2025 annual report should therefore not be read as a report solely for financial actors such as banks, payment service providers or gambling companies. On the contrary, it shows that the authorities’ focus is increasingly moving towards how companies are used as criminal tools, how supervision and operational cooperation are linked, and how new risk areas, such as sanctions-related money laundering, are being integrated into practical AML work.

At Morling Consulting, our AML lawyers and financial regulatory lawyers help companies structure and develop their AML work so that risks can be managed in time and processes work in practice. Where appropriate, we also provide support as an AML compliance consultant to help organisations implement proportionate controls across Europe.

For those who wish to read the report in full, the annual report is available here.