SEB has not sufficiently identified the risk of money laundering in its Baltic operations and has had deficiencies in its governance and control of the Baltic subsidiary banks’ anti-money laundering measures.
SEB is therefore being issued a remark and an administrative fine of SEK 1 billion.
FI's investigation, which covers the period 2015-Q1 2019, shows that SEB's subsidiary banks in the Baltics have been exposed to an elevated risk of money laundering. This is due in part to their geographic location but also because customers with a higher risk of money laundering have been responsible for a substantial portion of the subsidiary banks' business volumes and transactions.
FI's investigation also shows that the bank has had deficiencies in identifying and managing the risk of money laundering associated with some of their non-resident customers and resident customers with non-resident owners. The bank has also not been able to sufficiently rectify deficiencies identified by the bank's control bodies during the period. In addition, SEB's internal control functions and transaction monitoring have not had sufficient resources.
In recent years, SEB has taken action, and plans to take more actions, to rectify the deficiencies in the area of anti-money laundering. However, FI makes the assessment that, despite the bank's actions, the bank's deficiencies during the period under investigation have meant that the bank did not comply with the requirements laid down by law, and SEB is therefore receiving a remark and an administrative fine of SEK 1 billion.
FI also investigated how SEB's Swedish operations complied with the requirements set out in the anti-money laundering regulatory framework. In this matter, FI has ordered the bank to take certain actions to improve the monitoring of transactions.
"Despite the elevated risk of money laundering in the Baltics, the bank has done too little, too late," says Director General Erik Thedéen.
FI's investigation of SEB has been coordinated with the supervisory authorities in Estonia, Latvia and Lithuania. FI has investigated SEB's governance of the anti-money laundering work in the Baltic subsidiaries while the Baltic supervisory authorities have investigated the compliance of SEB's Baltic subsidiaries with the anti-money laundering regulatory framework in their operations. SEB's Estonian subsidiary is also receiving a precept and a fine from the Estonian financial supervisory authority for breaches of local anti-money laundering requirements. The bank's Baltic subsidiaries have also previously received a sanction in Latvia and an order to correct deficiencies in Lithuania.