Swedish Police have released a 2025 guide titled “The Money Transferer” detailing indicators of money laundering and terrorist financing in cash-to-cash transfers, urging vigilance among money transfer operators. The document outlines transaction red flags, customer profiles, and compliance obligations under EU AML regulations to combat financial crime networks.
The lead paragraph encapsulates the most critical facts: who (Swedish Police), what (release of a comprehensive 2025 PDF guide on money laundering and terrorist financing risks in money transfers), when (published for 2025), where (Sweden, with EU-wide relevance), why (to equip money service businesses with tools to detect illicit activities), and how (through detailed red flags and reporting duties). This A5-format document, accessible via the official Polisen website, targets money transfer operators handling cash-to-cash operations, emphasising proactive identification of suspicious patterns to prevent abuse by criminal networks.
Key Indicators of Suspicious Transactions
The guide identifies specific transaction characteristics warranting scrutiny. Transactions involving unusually high amounts relative to the customer’s profile, such as frequent large cash deposits or withdrawals without clear economic purpose, signal potential laundering. Multiple transfers to or from high-risk jurisdictions, including those under FATF grey or black lists, raise alarms, particularly if routed through intermediaries in countries like Afghanistan, Iran, or Myanmar. Rapid structuring of funds—breaking large sums into smaller ones below reporting thresholds—or inconsistent remittance purposes, like repeated “family support” claims mismatched with sender behaviour, are flagged as classic evasion tactics.
Suspicious Customer Profiles
Customer behaviours form a core focus of the advisory. Individuals exhibiting nervousness, reluctance to provide identification, or using false documents exemplify high-risk profiles. The document notes senders who avoid electronic trails, insist on cash-only, or frequent multiple agents in short succession to obscure origins. Recipients collecting funds on behalf of others without power of attorney, or those linked to proxy wallets in conflict zones, further heighten suspicion, as these patterns align with terrorist financing conduits.
High-Risk Jurisdictions and Networks
Geopolitical hotspots dominate the risk map. The guide lists countries with weak AML controls or active terror groups, advising enhanced due diligence for transfers involving Somalia, Syria, Yemen, and parts of West Africa . Networks often exploit diaspora communities, funneling funds via hawala-like systems disguised as legitimate remittances, with Sweden serving as a European hub due to its migrant populations . Emerging trends include cryptocurrency off-ramps disguised as cash transfers, blending virtual assets with physical cash to launder proceeds from ransomware or drug trades.
Compliance Obligations for Operators
Money transfer businesses face strict mandates. Operators must conduct customer due diligence (CDD), verify identities with official documents, and maintain records for five years . Suspicious activity reports (SARs) must reach Finanspolisen promptly via designated portals, with failure to report constituting a criminal offence. Training staff on red flags and implementing transaction monitoring systems form essential pillars, supplemented by risk-based approaches tailored to business volume.
Transaction Red Flags in Detail
Unexplained spikes in transfer volumes, such as a low-activity customer suddenly sending thousands of euros weekly, demand investigation. Seasonal surges unrelated to holidays or payrolls, or balancing inflows and outflows to net zero, mirror layering techniques used by launderers. Vague or changing remittance purposes, like shifting from “medical bills” to “business investment” without evidence, trigger alerts. Lack of supporting invoices, contracts, or beneficiary confirmation, especially for high-value sends, indicates potential straw man operations.
Beneficiary and Third-Party Risks
Beneficiaries evading direct contact or using runners to collect funds point to underground banking . Repeated collections by the same individual for multiple unrelated senders suggest nexus hubs in laundering chains. Cross-checks against sanctions lists from EU, UN, and OFAC are mandatory; matches or close associates necessitate transaction halts and immediate reporting.
Case Studies from the Guide
Real-world examples illustrate application. A hypothetical case involves a construction worker sending €10,000 monthly to Turkey without employment records, later traced to a drug cartel. Another details a student proxying funds to Syria, masked as tuition, funding extremist groups. These anonymised scenarios underscore the guide’s practical utility for frontline staff.
Role of Technology and Training
Digital tools aid detection. Implementing AI-driven anomaly detection and blockchain tracing enhances oversight. Mandatory annual training, scenario-based drills, and whistleblower protections ensure operator readiness.
Broader Context and EU Alignment
This 2025 edition aligns with updated EU AML regulations post-6AMLD, reflecting heightened focus on non-bank financial institutions. Sweden’s position as a FATF member amplifies its guidance’s influence across Europe, targeting the €15 billion annual remittance market vulnerable to abuse .
Reporting and Follow-Up Procedures
Operators submit SARs electronically via Polisen’s portal, including full transaction logs and KYC data . Urgent cases permit phone alerts to 114 14, followed by formal filings. Expect follow-up queries from Finanspolisen investigators; full cooperation mitigates liability [page 40].
Preventive Best Practices
Adopt a risk-based approach, escalating scrutiny for high-risk corridors. Integrate PEP screening and adverse media checks routinely.