JAK Medlemsbank receives a remark and an administrative fine

Finansinspektionen is issuing JAK Medlemsbank (516401-9969) a remark. JAK Medlemsbank must also pay an administrative fine of SEK 1.6 million.

Summary

JAK Medlemsbank (JAK or the bank) is a member's bank authorised to conduct banking business in accordance with the Banking and Financing Business Act (2004:297).

Finansinspektionen has investigated JAK's compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act (2017:630) and Finansinspektionen's regulations (FFFS 2017:11) regarding measures against money laundering and terrorist financing with regard to the rules on general risk assessment and customer due diligence.

Finansinspektionen's investigation shows that there have been significant deficiencies in JAK's compliance with the regulatory framework in terms of the design and scope of the bank's general risk assessment of how the business could be used for money laundering or terrorist financing. The bank has also violated several of the provisions of the anti-money laundering regulatory framework related to customer due diligence measures and has not stored its customer due diligence records in accordance with the regulatory framework.

The violations are of such a nature that they have increased the risk that JAK could have been used for money laundering and terrorist financing. According to Finansinspektionen, there are grounds on which to take a strict view on this type of violation. In this case, the investigation referred to a limited part of the anti-money laundering regulatory framework for a short period of time. It is not possible to draw any final conclusions about whether the violations have been systematic. Neither do the violations on any other grounds constitute reprehensible behaviour. Given this background and taking into consideration the relatively extensive measures that JAK has now taken and presented that it will take to rectify the measures, the sanction stops with a remark and an accompanying administrative fine of SEK 1.6 million. Finansinspektionen will follow up as part of its supervision that JAK has implemented the measures necessary to comply with the requirements of the anti-money laundering regulatory framework in the future.

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