7 steps to consider for successful AML reporting 2025

The periodic reporting of anti-money laundering (AML) is approaching soon in Sweden, and as a financial institution, you need to ensure that your company is fully prepared.

However, the reporting period can be time-consuming, making it challenging to complete the necessary documentation accurately and efficiently.

In this article, we spoke with Annika Lindström, Chief Operating Officer at Trapets, about how to prepare for the reporting period. With 15 years of experience in the banking and finance industry, Annika has served as Head of Operations at a bank and has held operational responsibilities for AML (anti-money laundering) and CTF (counter-terrorism financing).

The periodic reporting of AML - a short introduction

The periodic reporting of AML is an annual requirement for companies subject to the Anti-Money Laundering Act in Sweden. This requirement applies to various entities, including banks, insurance companies, and securities firms.

This reporting aims to allow Finansinspektionen, FI (the Swedish Financial Supervisory Authority), to monitor and assess the risks of money laundering and terrorist financing within financial institutions.

The reporting is conducted through FI's periodic reporting system, FIDAC (Finansinspektionen Data Collection), and it centralises around several topics related to your financial institution's compliance work, such as: 

• Customer due diligence (CDD): Information on customer due diligence measures and verification of customer identities.
• Transaction monitoring: Data on transactions, especially those flagged as suspicious.
• Risk assessments: Documentation of risk assessments and their outcomes.
• Internal controls: Information on internal controls and their effectiveness.
• Training: Details about AML training programs for employees.

Common questions in the reporting

Some of the common questions you encounter in the reporting revolve around:

• Customer information: How many customers do you have? How many of these customers are high-risk? 
• Transactions: How many transactions were conducted during the reporting period? How many of these were flagged as suspicious? 
• Risk assessments: How often do you conduct risk assessments? What methods do you use to assess risks? 
• Internal controls: What internal controls do you implement to prevent money laundering? How often are these controls reviewed? 
• Training: How many employees have undergone AML training during the reporting period? What does the training include? 

How to prepare for the AML reporting period 

1. Review your data on time 

Before getting started with reporting, ensure you are prepared for the process by first understanding the requirements and reviewing the latest updates and guidelines from FI. You can always find more information about reporting and news on their website.

Then, begin identifying the specific data you need for the AML reporting. This includes customer due diligence (CDD) information, transaction monitoring data, risk assessments, and internal controls documentation. Early identification helps you plan and gather the necessary information without last-minute rushes.

2. Get familiar with the new questions 

Finansinspektionen recently informed that they introduced 20 new questions for the report. These questions are used as the basis for risk-based supervisory planning and focus on distribution channels, staffing, and cross-border transactions.

Some of the new questions include: 

• Enter the company's product range, virtual IBAN.
• Are business relationships established through physical meetings with customers? 
• Are business relationships established through digital channels, phone or email/letter? 
• Are business relationships established through agents or third parties? 
• Is the sale or mediation of services and products through agents and or third parties? 

Ensure you familiarise yourself with the new questions and identify where to find the data and information to answer them. You can find more details about the updates for the reporting period in 2025 on FI’s website.  

3.  Involve key personnel 

Identify and involve the key personnel responsible for different aspects of the AML reporting process. Ask yourself which team members and departments will be involved and what role they will fill.

Some examples can include compliance officers, data analysts, and IT staff. Clear communication and collaboration among these roles are essential to ensure that your company covers all parts of the reporting process. 

4. Secure the required data

Ensure that all the required data is available and accessible. This involves verifying that the data is up-to-date and complete.

Make sure all customer information is updated and verified, compile the data on all transactions, especially those flagged as suspicious, and document the risk assessment process and the outcomes implemented at your company.   

5. Ensure where you can access the necessary data 

Identify in which system(s) the required data is stored and determine whether you can generate reports directly from these systems or if you need to manually compile data from multiple sources.

Don’t forget to assess the quality of the data to ensure it meets reporting standards. If necessary, consolidate data from different systems to create a comprehensive dataset. 

6. Keep an eye on the deadlines

Generally, the reporting period occurs in March of the following year (in this case, 31 March 2025). Yet, it’s a requirement that you collect all necessary data by the end of the current year (in this case, 31 December).  

7. Stay ahead by taking additional considerations 

The periodic reporting of AML requires careful attention to detail and thorough preparation.

As your ultimate goal is to prevent financial crime, there are several steps you can take into consideration to improve your reporting and compliance process at your company, such as: 

• Staying informed about any changes in reporting requirements or AML regulations (you can always find such information on FI's website). 
• Seeking advice from compliance experts or legal counsel if needed. 
• Utilising the three lines of defence model: For banks and financial institutions, internal audits are a regulatory requirement and part of a well-established framework including: 
  • First line: Operational management, including controls within business units. 
  • Second line: Compliance functions that monitor and facilitate the implementation of effective risk management practices by operational management. 
  • Third line: Internal audit functions that provide independent assurance on the effectiveness of governance, risk management, and internal controls. 

By following these steps, you can ensure that your financial institution effectively meets its reporting obligations to the Swedish Financial Supervisory Authority and maintains compliance with AML regulations.