Nordic market surveillance: cross-border compliance for Swedish firms

Discover what the regulatory landscape looks like across the Nordics, common challenges, and how to build a surveillance setup that holds up across all Nordic markets.

Published 2025-09-11
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Cross-border trading doesn’t wait for policy alignment. It moves fast, shifts across markets, and often puts compliance teams in a bind. 

One order can trigger oversight from four regulators. One suspicious trade might need to be explained in three languages. And one missed threshold can mean a reportable event goes unflagged.

For Swedish firms active across the Nordics, cross-border trading represents the day-to-day challenge of staying aligned with overlapping rules, formats, and expectations. 

In this article, we explain what the regulatory landscape looks like across the Nordics, common challenges, and how to build a surveillance setup that holds up across all Nordic markets.

Why cross-border compliance is important in the Nordics in 2025

For Swedish firms, trading rarely stops at the national border. Equity listings, derivatives, and fixed income instruments are often traded across Sweden, Denmark, Norway, and Finland - sometimes within the same trading day.

This means that Finansinspektionen (FI) oversight must often be balanced with the expectations of Finanstilsynet in Denmark and Norway, and Finanssivalvonta in Finland, alongside EU-wide rules from ESMA.

Cross-border obligations checklist

Operating across Nordic markets means navigating several layers of regulation at once. From EU-wide frameworks to local rules, firms need a structured approach that captures every obligation and ensures nothing falls through the cracks. The core requirements are:

  • MAR - Market abuse detection, STOR (Suspicious Transaction and Order Report) reporting, and insider list management for EU/EEA venues.
  • MiFID II/MiFIR - Transaction reporting, best execution, and governance for algorithmic trading.
  • MiCA - Crypto asset market abuse detection and licensing (where applicable).
  • AMLD - Anti-money laundering integration for suspicious trading linked to illicit funds.
  • Local regulator rules - Additional thresholds, reporting templates, or asset-specific monitoring requirements.
     

Nordic regulator comparison

Each Nordic regulator applies EU rules in its own way, while also setting local priorities that firms must be ready to address. Understanding these differences is essential for building a surveillance framework that works across borders. 

The key focus areas are:

In Sweden

Regulator: Finansinspektionen (FI)

Key local focus areas: Multi-venue surveillance, insider trading enforcement, and algorithmic governance

In Denmark

Regulator: Finanstilsynet

Key local focus areas: Market manipulation in equities and derivatives, cross-market STORs

In Norway

Regulator: Finanstilsynet

Key local focus areas: MAR compliance via EEA rules, cross-border market manipulation

In Finland

Regulator: Finanssivalvonta (FSA)

Key local focus areas: Crypto market oversight, insider lists, MAR Article 16 controls

While core regulations such as MAR and MiFID II remain consistent across jurisdictions, surveillance priorities can shift depending on recent enforcement trends or local regulatory focus. 

These shifts don’t always require system changes, but they often influence how surveillance is applied in practice. As Per Friberg, Senior Financial Crime Surveillance Officer at Trapets, notes:

“It’s more about what regulatory enforcement is in focus at a certain time or in a specific market. For example, if we take Norway, transactions in bonds are more in focus right now. You are not changing the system; you are maybe changing the human analysis of how to judge certain trading patterns.”

The same logic applies at the firm level. Internal priorities can change based on experience and risk exposure.

“If we think about a company that faced an insider trading case, the company most likely won't change the system, but rather the security procedures to strengthen their processes, such as who has access to inside information, for instance,”

- Per Friberg, Senior Financial Crime Surveillance Officer at Trapets

Common cross-border compliance challenges

  • Multiple STOR formats - Templates and submission processes vary by regulator.
  • Threshold differences - What triggers a report in one country may not in another.
  • Data privacy restrictions - Cross-border data sharing must comply with GDPR and local rules.
  • Language barriers - Evidence and communications may need to be translated for regulators.
  • Time zone coordination - Alerts in one market may require same-day reporting in another.

Best practices for Nordic cross-border surveillance

  1. Centralise data and rules - Use a single platform with configurable rule sets for each Nordic regulator.
  2. Automate multi-jurisdiction STOR Filing - Build workflows that adapt to local formats and submission methods.
  3. Integrate AML and market abuse monitoring - Link suspicious trades with financial crime alerts for a full regulatory context.
  4. Enable multi-language support - Equip analysts with tools for translation and localisation of evidence.
  5. Coordinate with local compliance leads - Maintain points of contact in each jurisdiction for faster case resolution.

Looking ahead: stronger Nordic regulatory cooperation

Nordic regulators are steadily moving toward closer cooperation, with a stronger focus on shared priorities and coordinated oversight. 

Areas where collaboration is expected to deepen are joint market abuse investigations, coordinated crypto and DeFi oversight under MiCA, and ESG-linked (Environmental, Social and Governance) market abuse detection in green bonds and carbon credits.

The Nordic regulatory landscape won’t get simpler anytime soon, but your approach to cross-border compliance can. With the right setup, you can reduce noise, standardise responses, and act quickly, no matter which market you’re dealing with.