The Swedish Anti-Money Laundering Institute, Simpt, was formed in 2016 by industry organisations within the financial sector. The Association of Swedish Finance Houses, the Swedish Investment Fund Association, the National Association of Swedish Savings Banks, Insurance Sweden, the Swedish Bankers' Association, the Swedish Securities Dealers Association and the Swedish Insurance Brokers Association are members of the institute.
Simpt is led by a steering group made up of the CEOs of the member organisations, and is chaired by the Swedish Bankers' Association.
The aim of Simpt is to produce guidance for financial companies in the interpretation and application of the rules and measures to prevent money laundering and financing terrorism. The objective is to establish good practice within this field.
The money laundering regulations have undergone changes, becoming increasingly extensive. There is often scope for interpreting the guidelines and questions sometimes arise in relation to their application, including when the rules come into conflict with other regulations. Overall, there is a great need for guidance in this area. Through Simpt, the industry is taking joint responsibility for these questions. This cooperation provides the right conditions for broad guidance with strong support, and for more effective application of the regulations.
The guidance is being drawn up jointly by the industry organisations and their member companies. However, it is up to each individual member company to decide how this guidance should be applied within its operations, based on its own circumstances.
The structure of the guidance is based on two main parts. One part contains basic descriptions of what is required in accordance with the money laundering regulations. This basic part also contains guidance on a general level, with descriptions of how the regulations are applied in practice within the industry. The other part consists of more limited guidance that is specific to individual operations, with descriptions of how the regulations are applied by the companies. The company-specific guidance is being written by expert groups made up of representatives from Simpt's member companies, and the basic guidance should be taken as a point of reference when reading this.
The guidance is being quality assured by a dedicated editorial board, consisting of experts on money laundering regulations. Another important aspect of the guidance work is the opportunity for parties other than the Simpt participants to give their views on the draft guidance (open consultation).
The guidance is being built up around various subject areas, such as general risk assessment and customer due diligence. Both the draft guidance and the adopted guidance will be published on an ongoing basis within adjacent subject areas. The guidance will emerge by degrees within the framework of a continuous process.
The guidance covers issues that the member companies have found it necessary to address, and is not intended to be comprehensive. The guidance is not legally binding. Simpt cannot accept responsibility for individuals' application of the guidance.