Supervision release 25 July 2022 – 37/2022

Financial Supervisory Authority’s recommendation on Ukrainian refugees’ identity verification and opportunities to access basic banking services

The European Banking Authority (EBA) has issued a statement regarding the status of refugees from Ukraine and their opportunities to access basic banking services. The EBA emphasises that financial institutions do not necessarily need to verify the identity of an Ukrainian refugee from a passport when providing basic banking services. Instead, they may be able to rely on alternative documentation from independent sources.

Like the EBA, the Financial Supervisory Authority (FIN-FSA) also considers it important that Ukrainian refugees have access to basic banking services. This release provides guidance on the application of the principles of the EBA statement in Finland.

Finland’s Money Laundering Act requires that supervised entities verify the customer’s identity. Pursuant to chapter 1, section 4, paragraph 7 of the Money Laundering Act, verification of identity means ascertaining the customer’s identity on the basis of documents, data or information obtained from a reliable and independent source. If a person has a Finnish personal identification code and a Ukrainian identity document (passport or identity card), their identity may be considered to be proven with sufficient reliability.

The Money Laundering Act also provides for the retention of data. Pursuant to chapter 3, section 3, subsection 3 of the Money Laundering Act, if the customer is a foreign national without a Finnish personal identification code, data on the customer’s travel document, for example, shall be retained. The travel documents accepted by Finland can be found on the website of the Ministry for Foreign Affairs.

Taking into account the above legal provisions, a financial institution or other supervised entity may decide for itself, based on its own risk-based procedures, which documents used to verify the identity of a Ukrainian refugee it considers to be acceptable in its own operations and when it should additionally carry out other checks, set controls or impose restrictions on the customer relationship.

The FIN-FSA recommends that the supervised entity, when preparing procedures for verifying the identity of a Ukrainian refugee, pay close attention to the authenticity of documents, their original purpose and the issuing process. For example, various travel documents may contain a note that identity has not been verified. The FIN-FSA also recommends that the supervised entity, when preparing procedures for verifying identity, take into account sections 4.9–4.11 of the EBA Guidelines on risk factors when people who have legitimate and credible reasons for their inability to provide traditional identity verification documents are involved. (PDF: 2021-5-28_Guidelines ML TF Risk Factors_FI -

The FIN-FSA reminds supervised entities that there is no need to provide a means of strong electronic identification in connection with a basic payment account if this appears to be too big a risk factor. When providing a means of electronic identification, it is also necessary to take into account that which is provided for in the Act on Strong Electronic Identification and Electronic Trust Services regarding documents acceptable for the identification of a natural person. In initial identification based solely on an identity document issued by an authority, acceptable documents are a valid passport or identity card issued by an authority of a member state of the European Economic Area, Switzerland or San Marino. If they so wish, providers of a means of identification may also use a valid passport issued by the authority of another state.

For further information, please contact:

  • Pekka Vasara, Head of Division, tel. +358 9 183 5513 or pekka.vasara(at) (until 4 August)
  • Jonna Ekström, Senior Legal Advisor, tel. +358 9 183 5531 or jonna.ekstrom(at) (from 1 August)