The Financial Action Task Force (FATF) published a mutual evaluation report on Sweden in 2006 and concluded that the legal framework prevailing in Finland to prevent money laundering and terrorist financing is generally comprehensive and encompasses most of the elements of the Vienna and Palermo Conventions. However, Sweden's anti-money laundering/combating the financing of terrorism (AML/CFT) regime does not appear to be effective in terms of implementation, evidenced from the low number of prosecutions and convictions. Preventive measures and the sanctions regime for financial institutions and designated non-financial businesses and professions (DNFBPs) are also generally broad, but with weak enforcement. The Swedish financial intelligence unit, the Financial Police, is found to be competent, but it lacks adequate resources. Other law enforcement officials in Finland are also competent. The country also has a comprehensive framework for national and international cooperation. The FATF in its 2006 report recommended, among other things, that Sweden broaden its AML/CFT regime to enable more robust supervision, broaden customer due diligence and record keeping requirements for financial institutions, designate AML/CFT supervisors for the DNFBP sector, and maintain more statistics on AML/CFT law enforcement. The FATF report finds that Sweden is in the process of aligning its legislation with the third European Union Money Laundering Directive, which requires member countries to fully implement all FATF recommendations and special recommendations.

General Overview

The FATF conducted a mutual evaluation of Sweden in 2005 and published its report in 2006. The report concludes that Sweden is fully compliant with 6 of the 40+9 FATF Recommendations on AML/CFT promulgated in 2003. It is largely compliant with 17 Recommendations and 4 Special Recommendations (SR), partially compliant with 12 Recommendations and 3 SRs, and non compliant with 3 Recommendations and 2 SRs. Recommendation (R) 9, pertaining to third parties and introducers, and R 34, pertaining to legal arrangements/beneficial ownership and control information, are not applicable in the Swedish context. The FATF report further notes that the legal framework to combat money laundering and terrorist financing in Sweden is "generally comprehensive" (p. 4); however, the system is not very effective, with low penalties and convictions for money laundering offences. The terrorist-financing offence is also broadly covered, but has some gaps. The powers and functions of Sweden's financial intelligence unit (FIU), the Financial Police (Finanspolisen, or FiPo), are "generally satisfactory" (p. 4), but the FiPo lacks adequate resources, relies on manual processes, and suspicious transaction reporting (STR) is not time-bound. The international cooperation framework is also "generally comprehensive" (p. 4). Customer identification measures in place are basic, though more comprehensive customer due diligence (CDD) requirements would be desirable. Record keeping and STR requirements are comprehensive and sufficient, though the system is not found to be very effective. Supervisory powers and powers of sanction are "generally broad" (p. 4), though they could be further expanded. Basic AML/CFT measures for designated non-financial businesses and professions (DNFBPs) are in place, but their effectiveness is in question, and they could be made more comprehensive.

According to the 2006 FATF report, the Swedish Financial Supervisory Authority (Finansinspektionen, or FI) is an integrated financial sector supervisor licensing and supervising banks and other credit institutions, insurance companies and intermediaries, securities companies, collective investment companies, and e-money businesses. It exercises prudential supervision over these entities and follows sector-specific supervision based on international standards like the Basel Core Principles (BCPs), the International Organization of Securities Commissions (IOSCO) Principles, and the International Association of Insurance Supervisors (IAIS) Insurance Core Principles (ICPs) to supervise AML/CFT compliance by the financial institutions. The FiPo is an intelligence unit within the National Criminal Police (Rikskriminalpolisen, or RKP), housed in the National Police Board (NPB). It was created in 1994, and became an Egmont Group member in 1995. The staff at the FiPo are "well-qualified and has a wide range of previous police experience" (FATF 2006, p. 6); however, their number is not adequate. The FATF report does note that after the FATF visit to Sweden, the supervisory resources of the FI were enhanced with the creation of a new unit comprising three staff and owning primary responsibility for AML/CFT supervision. On-site inspections have also received assistance from the Prudential Supervision Department of the FI.

Per the 2006 FATF report, the Swedish Penal Code has provisions to criminalize money laundering in accordance with the requirements of the 1988 United Nations (UN) Convention Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances (Vienna Convention), and the 2000 Convention against Transnational Organized Crime (Palermo Convention). The criminal laws of the land cover all FATF-designated categories of money-laundering offences, with the exception of participation in an organized criminal group. In addition, the Act on Measures against Money Laundering (as amended in 2005) contains stipulations on the AML obligations of a wide range of financial institutions, while the Act on Criminal Responsibility for Particularly Serious Crimes in Some Cases (hereafter CFT Act) has provisions on the CFT obligations of financial institutions. However, the AML/CFT legislation does not cover some credit card companies, such as American Express; and investment companies fall outside the scope of the CFT Act. Besides these AML/CFT Acts, the FI has also issued AML/CFT Regulations and Guidelines that are directly or indirectly enforceable and binding on financial institutions, and also incorporate sanctions for non-compliance. As for freezing terrorist assets, Sweden follows the Common Positions adopted by the EU, and the concomitant EU Council Regulations. The Security Council Resolution (S/RES/1267 of 1999) is implemented through Council Regulation (EC) No. 881/2002, which contains a list corresponding to the list maintained by the Al-Qaida and Taliban Sanctions Committee. This list is constantly updated. The obligations under S/RES/1373 of 2001 are implemented through Council Regulation (EC) No. 2580/2001.

Sweden is a member of the FATF, and its FIU is a member of the Egmont Group. Sweden has also signed and ratified the 1988 Vienna Convention, the 2000 Palermo Convention, and the 1999 Convention on the Suppression of the Financing of Terrorism. The FATF report provides some statistics on AML/CFT law enforcement in Sweden. Accordingly, the FiPo receives approximately 10,000 STRs per year, valuing approximately Swedish krona (SEK) 3.3 billion. In 2004, it sent 139 operative reports (indicating a specific crime conducted by specific natural persons) and 846 intelligence reports (indicating an event or a potential crime performed by natural persons) based on STRs to other law enforcement agencies in Sweden. The annual amount of the proceeds of crime has been estimated to be SEK 130 billion. Data received as of December 2005 state that there were 8 money laundering convictions, with 14 persons convicted that year. Also, there had been only one case of terrorist-financing conviction, with two people convicted, at the time of the FATF assessment. The FATF report finds that Sweden is in the process of aligning its legislation with the European Union's Third Money Laundering Directive which requires all member countries to fully implement all FATF recommendations and special recommendations.

The Principles

1. Legal Systems and Related Institutional Measures

CP

According to the 2006 FATF report, Sweden is largely compliant with R 1 and R 2 pertaining to the criminalization of money laundering. The Swedish Penal Code criminalizes money laundering in Sections 6, 6a, 7 and 7a of Chapter 9. The provisions cover the mandatory requirements of the Vienna and Palermo Conventions. In combination, the criminal laws of the land cover all FATF designated categories of money-laundering offenses except for participation in an organized criminal group. Also, conspiracy as an aggravated offence has not been clearly spelled out in the Penal Code. Punishment for money laundering is coupled with punishment for the predicate offence, since the distinction between the two is not clearly drawn. This can result in higher penalties for predicate crimes. Self-laundering is not punishable under Swedish law. Further, although the ancillary offense of "complicity" is applicable to the basic money receiving offense, it does not include the conspiracy to commit or attempt. Overall, the FATF report concludes that the money-laundering offense is not effectively implemented, with low convictions and penalties. The 2006 FATF report further finds that Sweden is largely compliant with SR II regarding the criminalization of terrorist financing. The report notes that "Sweden's criminalization of terrorist financing is largely in line with international standards" (p. 5), including the Terrorist Financing Convention. However, it does not fulfill all the SR II requirements. The FATF report recommends that Sweden amend its laws "to ensure that the offense specifically covers collecting or providing of funds in the knowledge that they are to be used (for any purpose) by a terrorist organisation or an individual terrorist without the need to demonstrate intent to commit a terrorist act" (p. 5).

The 2006 FATF report observes that Sweden is largely compliant with R 3 regarding confiscation, freezing, and seizing of the proceeds of crime, but only partially compliant with SR III regarding the freezing of funds used for terrorist financing. The Swedish Penal Code and special penal laws contain rules on forfeiture. Criminal confiscation includes a penalty of at least one year, property of equal value, instrumentalities of offense, and property derived from the proceeds of crime. Provisional attachment of property subject to confiscation suffers from limitations relating to the demonstration of cause that the property will be seized. Rules on seizure are "comprehensive" (p. 6), but there is little data on property forfeiture. As for freezing terrorist assets, Sweden follows the Common Positions adopted by the EU and the concomitant EU Council Regulations. The Security Council Resolution (S/RES/1267 of 1999) is implemented through Council Regulation (EC) No. 881/2002, which has a list corresponding to the list maintained by the Al-Qaida and Taliban Sanctions Committee. This list is constantly updated. The obligations under S/RES/1373 of 2001 are implemented through Council Regulation (EC) No. 2580/2001. However, as the FATF report observes, the EU regulation does not provide for freezing the assets of EU citizens or residents, and recommends that Sweden introduce a national provision to enable this and to allow requests for freezing from other jurisdictions.

Per the 2006 FATF report, Sweden is largely compliant with R 26 pertaining to the FIU and its functions, but only partially compliant with R 30 and R 32 regarding resources and statistics. The Swedish FIU, the FiPo, is an intelligence unit within the RKP, housed in the NPB. It was created in 1994, and became an Egmont Group member in 1995. The staff at the FiPo is "well-qualified and has a wide range of previous police experience" (FATF 2006, p. 6), but the number of staff is not adequate. STRs were found by the FATF team to be manually submitted, though Sweden was in the process of designing a new electronic system to receive and analyze STRs. As for guidance, the FiPo provided reporting forms and information on investigations and sentences relating to STRs to reporting entities, but no further guidance. The annual report of the FiPo contains statistics and money-laundering trends and techniques. However, the STRs with the FiPo can only be retained for a limited timeframe, and the procedures to be followed to retain them longer ultimately reduces the FiPo's effectiveness. The FATF report recommends that the timeframe limitation for storing STRs be removed.

According to the 2006 FATF report, Sweden is largely compliant with R 27 regarding law enforcement authorities; fully compliant with R 28 relating to their powers; and partially compliant with R 30 and R 32 regarding their resources, integrity, training, and statistics. The NPB, which is the central administrative and supervisory authority of the police service, is responsible for the technological development and support. It has two operative branches: (1) the Swedish Security Service (Säkerhetspolisen, or SÄPO); and (2) the RKP. The SÄPO "is responsible for protection of sensitive objects, counter-espionage, anti-terrorist activities and protection of the constitution" (p. 7). It conducts investigations and provides intelligence, resources, and know-how in the interest of national security. The RKP provides criminal investigation and intelligence support at the international as well as local levels. The National Economic Crimes Bureau (Ekobrottsmyndigheten, or EBM) is the investigative and prosecutorial authority in the area of economic crime, chiefly in metropolitan areas. The FATF report finds that Swedish law enforcement, prosecution, and other competent authorities "have comprehensive powers to compel production of, obtain access to, search premises for, and seize any documents needed during their investigations; as well as other investigative powers" (p. 7). However, the report questions the effectiveness of money-laundering investigations and prosecutions. In this regard, the FATF report recommends that the government adopt a more proactive approach to prosecuting money-laundering offenses, and provide more training and education to its law enforcement authorities in money-laundering offenses.

As the 2006 FATF report finds, Sweden is non-compliant with SR IX regarding cross border declaration and disclosure, since Sweden does not oblige the declaration or disclosure of cash or bearer negotiable instruments when entering or exiting the Swedish territory. The report, however, notes that the implementation of the EU Regulation on Cash Control in Sweden in the foreseeable future will bring Sweden closer to compliance with this Recommendation.

2. Preventive Measures - Financial Institutions

EN

The 2006 FATF report notes that Sweden is only partially compliant with R 5 on CDD. Customer identification and other AML obligations of a wide range of financial institutions are contained in the Act on Measures against Money Laundering (as amended in 2005), while the CFT Act has provisions on CFT obligations of financial institutions. However, the AML/CFT legislation does not cover some credit card companies, such as American Express; and investment companies fall outside the scope of the CFT Act. Besides these AML/CFT Acts, the FI has also issued AML/CFT Regulations and Guidelines that are directly or indirectly enforceable and binding on financial institutions, and also incorporate sanctions for non-compliance, if the latter is coupled with the financial institution "failing to conduct its business in a sound manner" (p. 7). The FATF report finds that though customer identification measures have been implemented in Sweden, full CDD requirements are not implemented. Customer identification is required when starting a business relationship with a client, for occasional transactions of €15,000 or more, if there are doubts of external influence on a customer transaction, or if the FI has grounds to suspect that a transaction involves money laundering or terrorist financing. Sweden has a lot of exemptions to the customer identification requirements that are otherwise very broad. There is no obligation to identify or verify beneficial ownership of a legal person, and no regulations pertaining to ongoing CDD, enhanced CDD, or CDD on existing customers. Further, AML/CFT regulations are not evidently effective, and the know-your-customer guidelines are not directly enforceable for FIs.

Sweden is found by the FATF report to be non-compliant with R 6 and R 7 as there are no CDD requirements or AML/CFT measures against establishment of relationship with politically exposed persons or cross-border correspondent banking relationship respectively. Sweden is largely compliant with R 8 relating to new technologies and non face-to-face business. It has legislation and regulation concerning non-face-to-face business relationships, and though there are no specific provisions requiring FIs to curtail misuse of technological developments, risk analysis and assessments imply that they be dealt with in accordance with the AML/CFT General Guidelines. As for R 9, it is not applicable in the Swedish context. Although financial institutions rely on third parties to conduct CDD for them, outsourcing agreements to do so exist under contract, thereby precluding the clauses in R 9.

According to the 2006 FATF report, Sweden is largely compliant with R 4 relating to secrecy laws and R 10 relating to record keeping; however, it is non-compliant with SR VII relating to wire transfer rules. The legal system enabling secrecy by financial institutions is "mostly satisfactory" (p. 8); however confidentiality clauses in domestic and international matters reduce the efficacy of the regime. Record keeping requirements are "generally broad" (p. 8), requiring FIs to maintain records for 10 years.

As the 2006 FATF report notes, Sweden is largely compliant with R 11 relating to unusual transactions and only partially compliant with R 21 relating to monitoring of higher risk countries. The AML/CFT Acts mandate financial institutions to examine closely all transactions suspected of money laundering or terrorist financing. Indirectly enforceable the FI's AML/CFT Regulations and Guidelines also instruct financial institutions to examine all unusual transactions, and put down notable findings in writing. Financial institutions are also required to keep records of STRs for one year, and file them under the Money Laundering Registers Act. As regards R 21, Financial institutions are not advised about the dangers of deficiencies in the AML/CFT regimes of other countries. Also, advisories on countries that continue to be non-compliant with the FATF Recommendations or are only insufficiently compliant with them are not legally binding.

The FATF report indicates that Sweden is fully compliant with R 14 relating to protection and no-tipping off; largely compliant with R 25 relating to guidance and feedback and SR IV relating to STRs related to terrorist financing; but only partially compliant with R 13 relating to STR, and R 19 relating to other forms of reporting. The report further notes that the AML/CFT obligation does not extend to certain credit card companies like American Express, and the CFT obligation does not cover investment funds. The limited scope of the terrorist-financing offence adversely impacts terrorist financing-related STRs by financial institutions. The report also finds that only a handful of financial institutions are submitting STRs, and therefore raises doubts on the efficacy of the implementation of R 13. Also, Sweden has not yet implemented a system wherein financial institutions may report currency transactions over a certain threshold electronically to a centralized body. To add to it, the FI has not issued sector specific guidelines to aid financial institutions in implementing and complying with their STR obligations, though it is taking steps to rectify the situation.

Per the 2006 FATF report, Sweden is largely compliant with R 15 relating to internal controls, compliance and audit. This is because indirectly enforceable Guidelines for licensed institutions, e.g. access to information by the compliance officer and establishment of an independent audit function, are not enforceable on certain registered financial institutions, like money remittance, exchange and deposit companies. Also, the financial institutions are not legally required to screen employees before hiring them to maintain high standards. Sweden is partially compliant with R 22 relating to foreign branches and subsidiaries. The FI can take corrective measures against a Swedish credit institution if it is informed by a host country supervisor of a breach of host country rule by the relevant institution. Financial institutions are not obliged to observe Swedish or FATF standards of AML/CFT measures at their foreign subsidiaries and branches, though they have an indirectly enforceable obligation to try to incorporate common group policies. Financial institutions are not required to pay extra attention to, and apply higher AML/CFT standards in, branches and subsidiaries operating in countries where FATF standards are not met or they otherwise differ from Swedish AML/CFT requirements. Financial institutions have only an indirectly enforceable obligation to inform the FI if they cannot apply their internal control regulations due to deficiencies in the host country laws and regulations.

As the 2006 FATF report notes, Sweden is partially compliant with R 18 relating to shell banks. Sweden does not legally prohibit financial institutions to enter into or continue correspondent banking relationships with shell banks. There is also no requirement for financial institutions "to satisfy themselves that a respondent financial institution in a foreign country is not permitting its accounts to be used by shell banks" (p. 167).

According to the 2006 FATF report, Sweden is largely compliant with R 17, R 25 and R 29 relating to supervisors, sanctions and guidance; and partially compliant with R 23, R 30, and R 32 relating to the supervisory and oversight system, resources, and statistics. The FI is an integrated financial sector supervisor licensing and supervising banks and other credit institutions, insurance companies and intermediaries, securities companies, collective investment companies, and e-money businesses. It exercises prudential supervision over these entities and follows the sector-specific supervisory core principles and standards like the BCPs, the IOSCO Principles, and the ICPs of the IAIS to supervise AML/CFT compliance by financial institutions. The FI also requires certain other financial sector entities like the currency exchange businesses, money transfer businesses and other financial services such as financial leasing companies to register at the FI. Licensed financial institutions in Sweden are subject to full supervision by the FI, including through on-site and offsite inspections, power to access records, documents and other information. The FI's powers of enforcement and sanction for non-compliance or inadequate implementation of the AML/CFT obligations are "generally adequate" (p. 9). They include broad administrative sanctions such as revoking a license or removing a board member or managing director; and criminal sanction for tipping off and non-compliance with the STR requirements. However, fit and proper tests only apply to board members and managing directors, and not to senior management. As for registered financial institutions, their registration requirements are limited and the FI's supervisory powers over them are also limited. It cannot conduct on-site inspections and has a limited range of sanctions for non-compliance. As for guidance and feedback, the AML/CFT Regulations/Guidelines have "relatively complete" (p. 9) guidance on the diverse AML/CFT obligations of entities, but they could be made sector-specific, include certain credit card companies and may need to be modified for fuller FATF compliance. The FATF report informs that after the FATF visit to Sweden, the supervisory resources of the FI were expanded with the creation of a new unit comprising three staff and owning primary responsibility for AML/CFT supervision. On-site inspections have also received assistance from the Prudential Supervision Department of the FI. The FATF report hopes that this change will lead to more number of inspections and cover a broader range of financial institutions.

Per the 2006 FATF report, Sweden is partially compliant with SR VI relating to money or value transfer services (MVTS). MVTS providers must register with the FI. However, they are not subject to a full range of AML/CFT obligations like the licensed financial institutions. Sweden is therefore advised to apply the full spectrum of AML/CFT requirements, backed by on-site inspections and sanctions, to the MVTS sector.

3. Preventive Measures - Designated non-Financial Business and Professions

NC

According to the 2006 FATF report, Sweden is partially compliant with R 12 relating to customer identification requirements for DNFBPs, and R 16 relating to the STR obligations of DNFBPs. The 2005 AML Act, as revised in 2005, contain AML requirements for most categories of DNFBPs, including casinos, real estate agents, dealers in precious metals and stones, lawyers and other legal professionals, auditors and tax advisors. However, they do not encompass accountants other than auditors and company service providers. Also, the CFT Act does not apply to the DNFBPs. The FI has also not promulgated AML/CFT Regulations/Guidelines for this sector. Customer identification is required when starting a business relationship with a client, for occasional transactions of € 15,000 or more, or if the DNFBP has grounds to suspect that a transaction involves money laundering. The FATF report recommends that Sweden require casinos to identify customers conducting transactions of € 3,000 and maintain records for at least five years. Also, all DNFBPs should be directly and mandatorily obliged to monitor large, unusual transactions, or those with no obvious economic purpose, and maintain records of their findings for at least five years. The FATF report further finds that the DNFBPs follow the same rules as financial institutions in reporting suspected money laundering to the FiPo, with the same "safe harbor" provisions. However, "tipping off" is not prohibited for advocates, associate lawyers at law firms and auditors once they have disclosed the information and investigations have started. This is a serious gap, per the report, and needs to be rectified. Reporting obligations for DNFBPs do not appear to have been effectively acted upon, with very few STRs from the sector. Also their voluntary obligation to terminate a relationship after submitting an STR conflicts with their duty to inform their supervisory authorities and client before terminating the contract.

Per the 2006 FATF report, Sweden is non-compliant with R 24 relating to the regulation and supervision of DNFBPs, since it does not have any designated monitoring authority or state-run organization for this sector. There are also no administrative sanctions deterring DNFBPs from AML/CFT violations. Sweden is largely compliant with R 25 relating to guidelines and feedback. Sweden does not have AML guidelines specifically for the casinos, real-estate agents, or company service providers, nor does it have CFT guidelines for the DNFBPs. As regards R 20 relating to other non-financial businesses and professions (NFBPs), the FATF report observes that Finland fully complies with this recommendation. The AML Act applies to tax advisors, natural and legal persons conducting professional commerce in antiques, art, scrap metal or means of transport, when they deal with cash payments of € 15,000 or more.

4. Legal Person and Arrangements & Non-Profit Organizations

EN

According to the 2006 FATF report, Sweden is partially compliant with R 33 pertaining to legal persons. The vast majority of legal entities in Sweden are required to keep information on shareholders and directors as well as registered partnerships and economic associations, and make them available to the public, though the information is neither timely nor updated regularly. Swedish law also does not require collection or availability of information on beneficial ownership, and the Swedish system does not provide sufficient access to timely and updated information on the same. As for R 34 relating to legal arrangements and beneficial ownership, this Recommendation is not applicable in the Swedish context. Trusts are not recognized under Swedish law, and no other legal arrangements similar to trusts exist in Sweden. As the 2006 FATF report notes, Sweden is only partially compliant with SR VIII relating to non-profit organizations (NPOs). This is because Sweden has not reviewed the adequacy of laws and regulations addressing the AML/CFT compliance by the NPO sector that may be potentially abused for terrorist financing. Some NPOs are subject to voluntary oversight through membership of the Swedish Foundation for Fundraising Monitoring; however, there are no specific laws against terrorist organizations posing as legitimate NPOs, or against the use of funds to support terrorist activities or organizations.

5. National and International Co-operation

CP

According to the 2006 FATF report, Sweden is largely compliant with R 31 relating to national cooperation and partially compliant with R 32 relating to statistics on national and international cooperation. Further, Sweden has "a generally comprehensive system for national and international co-operation" (p. 11).The FiPo effectively coordinates national cooperation, with engagements with at least 51 other law enforcement bodies, through information exchange and participation in various crime fighting and intelligence projects. However, the FATF report recommends more cooperative projects targeting money laundering and terrorist financing issues; a more pro-active approach to AML/CFT policy level coordination, and regular reviews of the effectiveness of the AML/CFT regime. Sweden, per the 2006 FATF report, is largely compliant with R 35 and SR I relating to Conventions and other UN Special Resolutions. It has signed and ratified the Vienna, Palermo and CFT Conventions of the UN, and has implemented almost all relevant provisions of the Conventions to ensure FATF compliance. However, some gaps in implementation remain and certain provision could be further strengthened.

As the 2006 FATF report notes, Sweden is largely compliant with R 36 and SR V relating to mutual legal assistance (MLA) for money laundering and terrorist financing cases, respectively, as also R 38 relating to MLA on confiscation and freezing and fully compliant with R 37 relating to dual criminality. Swedish authorities "can provide a wide range of mutual legal assistance" (p. 11). However since MLA requires dual criminality, "it is not clear how effectively Sweden could execute coercive measures relating to requests involving conspiracy to commit basic money laundering and collecting/providing funds/assets to be used by a terrorist organisation or individual terrorist" (p. 170). Sweden also does not have an asset forfeiture fund to collect confiscated property to be used for law enforcement or developmental purposes. Per the 2006 FATF report, Sweden is fully compliant with R 39 relating to extradition and R 37 relating to dual criminality for extradition and largely compliant with SR V relating to international cooperation. The requirement for dual criminality for extradition poses the same dilemma for Sweden, as it does for MLA. Sweden also does not maintain sufficient statistics on the number of formal requests for assistance received by the FiPo, nor does it maintain statistics on MLA and extradition requests made or received for AML/CFT cases, spontaneous referrals made by the FiPo to foreign authorities, and law enforcement requests relating to AML/CFT. This makes Sweden only partially compliant with R 32 relating to statistics. R 40 relating to other forms of international cooperation is, however, fully observed by Sweden, as noted by the 2006 FATF report.