On 25th July, FATF published an update report saying that since the country’s 2017 evaluation progress made had caused FATF to re-rate the country on 10 of the 40 Recommendations and moved the country from an enhanced to a regular follow-up.  The report analyses Sweden’s progress in addressing the technical compliance deficiencies identified in the mutual evaluation report.   FATF has re-rated Sweden on –

2 – National cooperation and coordination

9 – Financial institution secrecy laws

12 – Politically Exposed Persons (PEP)

16 – Wire transfers

17 – Reliance on third parties

18 – Internal controls and foreign branches and subsidiaries

19 – Higher-risk countries

24 – Transparency and beneficial ownership of legal persons

25 – Transparency and beneficial ownership of legal arrangements

29 – Financial Intelligence Units (FIU)

The report also looks at whether Sweden’s measures meet the requirements of FATF Recommendations that have changed since the 2017 evaluation, taking into account any new measures since the mutual evaluation.  FATF agreed to maintain the ratings of –

  • Partially Compliant for Recommendations 7,
  • Largely Compliant for Recommendation 8
  • Compliant for Recommendation 21.


Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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