AML program

Ett AML-program omfattar riskbedömning, kundkännedom, interna rutiner, rapportering till the Swedish Financial Intelligence Unit (Finanspolisen) and staff training. In practice this means a documented risk assessment, know your customer controls, aml internal controls and suspicious activity reporting.

Firms within scope of the Anti-Money Laundering Act must have an AML program. This includes, for example, banks, payment service providers and estate agents, and the requirement applies from commencement of operations.

Start with a money laundering risk assessment, then tailor procedures and aml internal controls to the firm’s specific risks. Involve senior management, define escalation and reporting lines (including suspicious activity reporting) and ensure a maintained aml training program. To work long term, the program must be reviewed and updated regularly.

Training ensures all employees understand their roles and obligations. A well-designed aml training program helps staff recognise red flags and follow reporting procedures in practice, supporting ongoing customer due diligence.

Senior management holds overall responsibility, with an appointed function often handling day-to-day operations. Responsibilities include ensuring risk assessments, kyc procedures and reporting obligations are followed and properly documented.

The AML program is the consolidated framework that satisfies statutory requirements, whereas internal guidelines are instructions for the organisation. In practice, the AML program is more detailed and includes mandatory components, such as:

• A risk assessment tailored to the business
• Procedures for know your customer and customer due diligence
• AML internal controls and reporting procedures
• Training and follow-up

These elements together form an anti money laundering program capable of meeting the eu anti money laundering directive and the swedish anti money laundering act, with clear suspicious activity reporting and documented governance.