Penalty payment of EUR 10,000 and public warning for Halgan Services Oy due to omissions concerning compliance with anti-money laundering regulationsThe omissions relate to various obligations under the regulations on preventing money laundering and terrorist financing. Specifically, this concerns deficiencies in the assessment of risks, in the risk-based assessment of customers, in customer due diligence, in the retention of customer due diligence data and in the enhanced customer due diligence obligation.
The Financial Supervisory Authority (FIN-FSA) has imposed a penalty payment of EUR 10,000 on Halgan Services Oy and issued a public warning to it, because it has not satisfactorily performed customer due diligence, retention of customer due diligence data or enhanced customer due diligence obligation for the purpose of meeting the requirements of the Act on Preventing Money Laundering and Terrorist Financing. Neither has the company prepared a satisfactory risk assessment or made a satisfactory risk-based assessment of its customers.
The FIN-FSA considers the company’s most serious omission to be its failure to comply with the enhanced customer due diligence obligation when acting on requests for money remittance to countries specified by the European Commission as being high risk. This money remittance service provided by the company is essentially a high-risk activity in terms of money laundering and terrorist financing.
In the comprehensive assessment of the amount of the penalty payment, the factors taken into account include the nature, extent and long duration of the omissions concerning key obligations for the prevention of money laundering.
The FIN-FSA has, in addition, issued a public warning to the company about failure to comply with the customer due diligence obligation set out in the Act on Payment Institutions.
The omissions came to light during an inspection by the FIN-FSA in 2020–2021, the aim of which was to examine how the company discharges its obligation to comply with the Act on Prevention of Money Laundering and Terrorist Financing.
The penalty payment is payable to the State.
The FIN-FSA’s decision is not legally binding, as the company has the right to appeal against the decision of 12 April 2022 to the Helsinki Administrative Court within 30 days of receipt of notice of the decision.
FIN-FSA decision (PDF, in Finnish)