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Anti-Money Laundering Policy


Bambora AB is a payment institution subject to the Swedish Payment Services Act (2010:751) and the Money Laundering and Terrorist Financing (Prevention) Act (2017:630). This means that we are responsible for preventing our products and services from being misused to launder money or finance terrorism. The rules for combating money laundering and the financing of terrorism are based on an EU Directive. Read more on the website of the Swedish Bankers’ Association.

What are money laundering and the financing of terrorism?

Money laundering is when someone tries to convert money or other property that comes from criminal activities to make it look as if the money was lawfully earned.

Financing of terrorism means supporting terrorism through financial means. It is not just about contributing money, as collecting, providing and receiving money that is to be used for terrorism also represent financing of terrorism.

Money laundering and the financing of terrorism are international problems that constitute serious threats to financial systems, the economy and public safety.

We take our social responsibility extremely seriously, and therefore consider preventing criminal activities and criminals from exploiting the financial system to be an important part of our work.

We are obliged to ask you questions

We have a responsibility to assess whether there is a risk of our products and services being used for money laundering and the financing of terrorism. We are required to have very good knowledge of our customers and their affairs, and consequently, we ask questions of all our customers. This is comparable to the security check at an airport. Everyone has to undergo it so that the security staff can identify anyone who needs closer scrutiny. If we act together, we can help stop criminal activities.

Both new and existing customers need to answer KYC questions (see next section), and all the information we learn about you is treated in confidence. In certain cases, we may need to ask supplementary questions and request different types of documentation from you.

The questions we ask and the documentation or verification we request may differ from that which other companies require as every company’s approach is based on its own internal assessments and rules.

Standard KYC and money laundering questions

What is KYC?

The new Money Laundering and Terrorist Financing (Prevention) Act (Anti-Money Laundering Act) makes us more responsible for understanding the purpose of our customers’ business affairs and transactions. Consequently, we must ask questions of all our customers. These questions are called Know Your Customer (KYC) questions. We need to keep the information about our customers up to date and may therefore ask you to update your company’s details at regular intervals. More information about the new Anti-Money Laundering Act and the KYC process is available at the website of Finansinspektionen (FI – the Swedish Financial Supervisory Authority).

Why do you ask whether I am a Politically Exposed Person (PEP)?

Under the Anti-Money Laundering Act, we need to know which of our customers are Politically Exposed Persons. Such a person is deemed to be in a position that may entail a risk of being exploited for passive corruption, among other things.

A Politically Exposed Person is a person who holds or has held important public functions in a state or an international organisation. Family members and persons known to be close associates of persons with such an important function are also subject to the legislation.

Important public functions include:

  • Heads of state, heads of government, ministers and deputy or assistant ministers

  • Members of parliament

  • Members of governing bodies of political parties

  • Judges in high-level judicial bodies, the decisions of which are not subject to further appeal

  • Senior officers

  • Swedish national auditors, members of the Executive Board of the Riksbank, senior civil servants at national audit authorities or members of the board of a central bank

  • Ambassadors and diplomatic envoys

  • Members of the administrative, management or supervisory bodies of state-owned enterprises

  • Senior positions in an international organisation

Persons known to be close associates means:

  • A person who, jointly with a PEP, owns or otherwise has a controlling interest in a company

  • A person who has or has had a close connection to a PEP in some other way – this does not need to be a business relationship

  • A person who is the sole owner of, or exercises influence over, a company that was actually formed for the benefit of a PEP

The term PEP also applies to foreign equivalents to the functions above. Read more at the website of the Swedish Bankers’ Association.

What does beneficial owner mean?

A beneficial owner is a natural person who, alone or with a family member*, ultimately owns or controls a legal entity, for example a limited company. A beneficial owner may also be a natural person who profits from someone else acting for them.

A beneficial owner is a person who:

  • Controls more than 25% of the legal entity based on ownership of shares, other participations or membership, or

  • Is entitled to appoint or dismiss more than half of the legal entity’s Board members or corresponding officers, or

  • Exercises control as described above by means of a contract, articles of association, articles of partnership or similar, or

  • Exercises control in their capacity as founder, trustee, beneficiary or Board member equivalent to an officer, in a foundation or trust or a similar legal construction

  • May have indirect ownership by means of ownership of other legal entities which, in turn, own the customer

*Family member is defined as a spouse, registered partner, cohabitant, children and their spouses, registered partners or cohabitants, and parents.

If there is no beneficial owner, one of the following will be deemed to be the beneficial owner:

Chair of the Board of Directors, CEO, trustee or senior partner.

What does the tax domicile of the beneficial owner mean?

Tax domicile is the country in which you pay tax and declare your income, usually where you live and work. However, you may have a tax domicile in several countries.

What does the tax domicile of a company mean?

A company often has its tax domicile in a country in which it pays or should pay tax under the legislation of the country, as the company has its registered office or management there, or the company is registered there, or similar rules apply.

What is the Common Reporting Standard (CRS)?

CRS is a global standard for the automatic exchange of information on financial accounts. It means that banks must identify financial accounts held by customers with a tax domicile outside Sweden and the US.

Can I call to obtain more information?

Yes, call us on +46(0) 10-10 66 000 and we will help you. Lines are open on weekdays 09:00–20:00 and Saturday 10:00–14:00.