If your operations are subject to the reporting obligation, you must know your customers and monitor the customer relationship throughout its duration. The monitoring must be comprehensive enough that you are able to detect deviations from the customer relationship’s typical transactions.
If you notice an abnormal transaction, you must examine the basis and purpose of the transaction in further detail and, if necessary, the origin of the assets related to the transaction. A transaction can be unusual, for example, if it does not fit the customer’s profile or is different from the customer’s previous transactions.
To test whether a transaction should be considered unusual, you can compare it against
- transactions that are typical of the industry,
- transactions that are typical of other similar customers, or
- typical transactions involving other similar products or services.
If your conclusion is that there is something suspicious about the transaction, report it immediately to the National Bureau of Investigation’s Financial Intelligence Unit. Even the slightest suspicions must be reported. It is not your responsibility to determine whether or not a crime has been committed.
Always file a report if:
- the transaction still appears suspicious after you have received an explanation from the customer,
- you decide to refuse a transaction based on its unusual or suspicious nature, or
- you find the transaction suspicious after it has already taken place.
Do not tell the customer about your report. Keep the evidence that you collected for your report for a period of five years and store it separately from other customer documents.
Where should I send my report?
The body responsible for handling anti-money laundering reports in Finland is the National Bureau of Investigation’s Financial Intelligence Unit. It takes care of all suspected cases of money laundering and terrorist financing and produces information to combat the phenomena.
The report is made via an online reporting application to which you must register. A link to the reporting tool is provided at the bottom of this page.