ARTICLE
3 December 2025

Regulator's Audit Findings On Nordea Bank's Sanctions Compliance

DM
Duane Morris LLP

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Finland's Financial Supervisory Authority has published the results of an "audit" on Nordea Bank in relation to the bank's compliance with the asset freeze and export prohibition aspects of the EU's Russian sanctions.
Finland International Law
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Finland's Financial Supervisory Authority has published the results of an "audit" on Nordea Bank in relation to the bank's compliance with the asset freeze and export prohibition aspects of the EU's Russian sanctions.

The result of the audit was a finding of a "very significant lack of information obtained and retained by the bank", with a lack of updating on the information that was obtained. In addition, "shortcomings of great significance" were found in relation to customer due diligence, and a lack of adequate assessment of the risk of sanctions circumvention including payments that involved "a high risk country from the perspective of sanctions evasion".

The announcement from the FIN-FSA does not indicate whether any further regulatory action will be taken.

My thanks to Louis Vargas of the Network for Financial Crime Prevention for informing on this published audit.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.

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