FIN-FSA imposes penalty payment on S-Bank Ltd and issues public warning to FIM Asset Management Ltd for omissions in customer due diligence


The omissions relate to obligations under regulations on the prevention and investigation of money laundering and terrorist financing. The main issue is shortcomings in customer due diligence. The Financial Supervisory Authority (FIN-FSA) considers that appropriate assessment and ongoing monitoring of the risks of money laundering and terrorist financing require adequate risk management procedures as well as up-to-date and comprehensive customer due diligence data.

The FIN-FSA has imposed a penalty payment of EUR 980 000 on S-Bank Ltd because its risk-based approach has not been sufficiently comprehensive to meet the requirements of the Act on Detecting and Preventing Money Laundering and Terrorist Financing nor had it obtained adequate customer due diligence data. In addition, there have been shortcomings in S-Bank Ltd’s information systems and processes.

At the same time, the FIN-FSA has issued a public warning to FIM Asset Management Ltd because it had not obtained adequate customer due diligence data.

The omissions were revealed in an inspection made by the FIN-FSA in 2017–2018 related to the arrangement of ongoing monitoring, as referred to in the Act on Detecting and Preventing Money Laundering and Terrorist Financing. The inspection made at S-Bank Ltd assessed the customer due diligence data of the banking group, at which time the inspection was extended to cover FIM Asset Management Ltd. The FIN-FSA regularly inspects the procedures of supervised entities in respect of the adequacy of the prevention of money laundering and terrorist financing.

Based on the inspection findings, the FIN-FSA has no reason to suspect that money laundering offences referred to in the Criminal Code have been committed in the activities of S-Bank Ltd or FIM Asset Management Ltd.

For further information, please contact:

Sonja Lohse, Chief Adviser and Pekka Vasara, Head of Division

Requests for interviews are coordinated by FIN-FSA Communications, tel. +358 9 183 5030, weekdays 9.00–16.00.


  • Decision of the FIN-FSA: S-Bank Ltd (pdf) (in Finnish)
  • Decision of the FIN-FSA: FIM Asset Management Ltd (pdf) (in Finnish)

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Finanssivalvonta, or the Financial Supervisory Authority (FIN-FSA), is the authority for supervision of Finland’s financial and insurance sectors. The entities supervised by the authority include banks, insurance and pension companies as well as other companies operating in the insurance sector, investment firms, fund management companies and the Helsinki Stock Exchange. We foster financial stability and confidence in the financial markets and enhance protection for customers, investors and the insured.

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