2023-01-01 | FIN-FSA Regulations and guidelines 4/2023

Customer due diligence related to compliance with sanctions regulation and national freezing orders

The Finnish Financial Supervisory Authority (FIN-FSA) issued Regulations and guidelines 4/2023 to establish requirements for customer due diligence in the context of sanctions regulation and national freezing orders. These guidelines, which became valid on 1 March 2024 and were updated on 8 January 2025, apply to supervised entities within the financial sector to ensure compliance with legal obligations. The document serves as a comprehensive guide for implementing risk management and due diligence procedures aligned with current regulatory frameworks.

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Regulations and guidelines 4/2023 (pdf)

Customer due diligence related to compliance with sanctions regulation and national freezing orders

valid from 1 March 2024 until further notice

date of change 8 January 2025

Regulations and guidelines 4/2023 Customer due diligence related to compliance with sanctions regulation and national freezing orders (version 2)

More information

Request for Comments (FIVA/2023/951) Regulations and guidelines: Customer due diligence related to compliance with sanctions regulation and national freezing orders

Summary of comments

FIN-FSA regulations and guidelines

Commencement of activities

Payment institutions and persons providing payment services without a license

Consumer credit providers and peer-to-peer lending intermediaries

Organisation of supervised entities’ operations

Organisation of alternative fund management activities and procedures

Outsourcing in supervised entities belonging to the financial sector

Reporting of mortgage bank operations

Alternative fund managers

Organisation of investment services activities and procedures

Preventing Money Laundering and Terrorist Financing

Customer due diligence related to compliance with sanctions regulation and national freezing orders

Risk management

Risk reporting by credit institutions

Reporting of funding plans

Management of operational risk in supervised entities of the financial sector

Management of credit risk and assessment of creditworthiness by supervised entities in the financial sector

Risk management concerning mortgage bank operations

Accounting, financial statements and management report

Regulations and guidelines on accounting, financial statements and management report: Insurance companies, occupational pension insurance companies, insurance associations, insurance holding companies, branches of third-country insurance companies and pension institutions established by law

Regulations and guidelines on accounting, financial statements and management report: Pension funds and pension foundations

Regulations on accounting, financial statements and management report: Sickness funds and funeral and severance benefit funds

Financial sector regulations and guidelines on reporting of financial information (FINREP)

Accounting, financial statements and management report of the financial sector

Capital adequacy

Common European Reporting (COREP)

Regulations and Guidelines related to the Capital Requirements Regulation

Prudential reporting for investment firms (IF)

Conduct of Business

Methods used to calculate the maximum compensation charged for early repayment of housing loans

Disclosure of expenses and returns of long-term savings agreements and insurance policies

Calculation of maximum loan-to-value ratio

Procedures to be followed in banking services

Management of default risks in consumer lending

Operations of securities markets

Takeover bid and the obligation to launch a bid

Public insider register of market participants, occupational pension insurance companies and fund management companies

Trading parties from third countries

Regulations and guidelines on disclosure obligation

Insurance operations

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