7 steps to consider for successful AML reporting in 2026

The annual anti-money laundering (AML) reporting period is currently underway in Sweden. As a financial institution, you need to ensure that your company is fully prepared for this timeframe. 

While periodic AML reporting is a familiar obligation for compliance teams, the process can still present challenges. 

Required information is often spread across several systems, and multiple functions may need to contribute before the report can be finalised.  

Data validation, coordination, and documentation can therefore require significant effort during a limited time frame. 

In this article, we'll look at the key aspects of AML periodic reporting for 2026 and highlight seven practical steps to help you prepare. 

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 banks,insurance companies, securities firms, and other obliged entities. 

The purpose of the reporting is to allow Finansinspektionen (FI), the Swedish Financial Supervisory Authority, to monitor and assess money laundering and terrorist financing risks within the financial sector. 

For the 2026 reporting period, the following dates apply: 

• Reporting can begin from 1 January 2026.
• The final submission date is 31 March 2026.
• The reporting is based on the balance sheet date of 31 December 2025.  

Reporting is carried out through FI’s periodic reporting system, FIDAC (Finansinspektionen Data Collection). The submission covers several areas of AML work, including: 

• 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 eight new issues related to: 

• The company's organisation;
• The freedom to provide services;
• Frozen assets.

These questions support risk-based supervisory planning and focus on topics such as distribution channels, staffing, and cross-border activity. 

Some of the new questions include: 

• Whether the company is part of a group with more than one financial entity.
• Whether the company acts as a parent company.
• Whether customers reside in another EU member state through the freedom to provide services. 

The section on frozen assets requires information such as: 

• Applicable EU sanctions regime;
• Sanction-listed name or company;
• Account or asset value in EUR as of 31 December 2025;
• Date of freezing;
• Case or file reference;
• Description of what is frozen.

Ensure you familiarise yourself with the new questions and identify where to find the data and information to answer them.  

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.  

Ensure 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 

The final submission deadline for the 2026 reporting period is 31 March 2026. All reported figures must be based on the balance sheet date of 31 December 2025. 

Build an internal timeline with checkpoints to ensure that data collection, review, and approval are completed well before the deadline. 

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 Finansinspektionen and maintains compliance with AML regulations.