Money laundering (AML)

Money laundering is the process of concealing the criminal origin of funds and integrating them into the legitimate financial system.

We explain – what is money laundering?

Money laundering means converting assets derived from criminal activity so they appear legitimate. The concept is regulated under the Anti-Money Laundering Act and the EU Anti-Money Laundering Directive. The process is commonly described as the three stages of money laundering: placement, layering and integration. These stages cover how funds enter the financial system, are then moved to obscure traceability, and are finally mixed with lawful assets. For complex matters or investigations, an experienced money laundering lawyer can provide specialist advice on what is money laundering in practice and the evidential thresholds involved.

When does money laundering become an issue?

The question of money laundering is particularly relevant for banks, financial institutions, law firms and other businesses subject to the Anti-Money Laundering Act. Triggers include large cash deposits, complex transaction chains or unusual patterns in business relationships. Property deals, company formations and cross-border transfers are also typical scenarios where red flags arise and a money laundering lawyer may be engaged.

Illustration of money laundering, showing illicit funds being moved and disguised as clean money, representing anti-money laundering (AML) compliance and financial crime prevention.

Points to consider regarding money laundering

Obliged entities must have clear procedures to identify, assess and report suspicious activity. The following measures are key and align with a risk based approach AML framework, robust AML internal controls and AML documentation requirements.

  • Perform customer due diligence requirements and risk assessment before entering into a business relationship.
  • Monitor transactions on an ongoing basis to detect anomalous behaviours.
  • Document all procedures and ensure staff receive appropriate training.
  • Establish internal channels for reporting suspected activities.
  • Implement systems that support detection of layering and other advanced methods, including placement layering integration typologies.
  • Ensure the business meets all obligations under anti money laundering law for effective financial crime prevention.

By working systematically with these measures, organisations can prevent misuse for criminal purposes, strengthen financial crime prevention and meet statutory obligations.

Frequently asked questions about money laundering

Money laundering is concealing the origin of criminally obtained funds and making them appear lawful. It can also occur in reverse, for example by using lawfully earned funds to pay undeclared wages. If in doubt, consult a money laundering lawyer to assess indicators and reporting thresholds.

The three stages are placement, layering and integration. Placement introduces illicit funds into the financial system, layering moves the money through various transactions to obscure origin, and integration returns it as seemingly legitimate assets.

Obliged entities must report suspicions to the Swedish Financial Intelligence Unit (Finanspolisen). This applies when unusual transactions or behaviours do not match the customer’s profile. Examples include:

  • Large cash deposits without a clear explanation
  • Customers using complex corporate structures
  • International transfers with unclear purposes

Prevention requires a risk based approach AML and systematic procedures. Key actions include:

  • Conduct regular risk analysis of customer relationships and update customer due diligence requirements
  • Train staff to recognise red flags and typologies across placement, layering and integration
  • Use digital monitoring tools and strong AML internal controls for transactions
  • Ensure comprehensive records in line with AML documentation requirements

The obliged entity, i.e. senior management, bears ultimate responsibility. Larger organisations often appoint a specific function or officer to oversee compliance, but management remains accountable.

Money laundering seeks to legitimise criminal proceeds, whereas terrorist financing involves providing or raising funds for terror-related activities. Although both fall within anti money laundering law, the purpose differs: money laundering hides past crime, while terrorist financing enables future acts. Both require strong controls and supervision, for example through customer due diligence, transaction monitoring and reporting of suspicious activity, in line with the EU anti money laundering directive.

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If you prefer phone, please feel free to contact Felix Morling at +46 70 444 42 85

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