title: Finland Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/finland/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # Finland FI schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 73 sourced findings · 129 sources in the cumulative register 14 Modules baseline.modules[] 73 Findings modules[].findings[] 8 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) ** Law made at European Economic Area level** that applies in Finland is covered once, on the [European Economic Area](https://payments.gi/jurisdictions/european-economic-area/) page. This page covers Finland’s own layer: implementation, national authorities, national options and local enforcement. ## Jurisdiction brief ###### Latest update · 18 October 2026 #### Lead Signal Finland's banking M&A regulatory framework materially tightened on 1 October 2026, when a new chapter of the Act on Credit Institutions implementing CRD6 entered into force. The new chapter requires credit institutions to give advance written notification to FIN-FSA before material asset or liability transfers at or above a 10% balance-sheet-value threshold (15% for intra-group transfers), material-holding acquisitions, and mergers or demergers of credit institutions, with such transactions subject to FIN-FSA's assessment and approval process. This is a structural change to how banking-sector consolidation and restructuring activity in Finland will be supervised going forward, rather than an isolated enforcement event. #### Other Developments **FIN-FSA penalty-determination principles updated.** FIN-FSA published updated principles on 1 October 2026 for determining the size of penalty payments and administrative fines, giving greater weight to early and comprehensive cooperation by the responsible party, applicable across all FIN-FSA-supervised sectors. This is not payments-specific but informs how any future supervisory enforcement matter touching a bank or payment institution would be sized. **Alexandria Group Oyj penalty overturned on appeal.** The Helsinki Administrative Court accepted Alexandria Group Oyj's appeal and annulled FIN-FSA's EUR 1,000,000 penalty of June 2025, ordering FIN-FSA to pay EUR 30,000 toward the firm's legal costs; the ruling is not yet final. Alexandria Group Oyj is a non-payments investment firm, so the relevance to the payments sector is limited to the general signal this sends about FIN-FSA's enforcement posture and its exposure on appeal, rather than any direct payments-sector finding. #### Cross-Monitor Connections The CRD6-driven notification regime is a prudential banking development with payments-sector relevance where a bank-PSP's parent or group structure is involved in a qualifying transfer, acquisition, or merger; this is a market-access and structural-change consideration for bank-model PSPs specifically, distinct from the non-bank PI/EMI licensing track where this new notification obligation does not apply. The financial-integrity monitor separately tracks FIN-FSA's penalty-determination update as a cross-sector compliance-technology development. #### Outlook The practical effect of the CRD6 notification regime will become clearer as FIN-FSA's assessment and approval process is tested against actual transactions; no such transaction has yet been reported under the new regime. Whether FIN-FSA's updated penalty-determination principles materially change outcomes in future enforcement matters, including any appeal following the Alexandria Group Oyj precedent, remains to be observed. _3 earlier updates not shown here._ ###### Standing brief · as of 4 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Finland's FIN-FSA flagged payment service providers as having the most room for improvement in complying with sanctions regulations and national freezing orders in a February 2026 sanctions risk-assessment update, a finding that lands directly on top of the 2024 NYDFS settlement that fined Nordea Bank Abp USD 35 million for correspondent-banking AML failures. The gap is structurally significant because Nordea's Helsinki head office is Finland's principal correspondent-banking gateway, the same institution whose NYDFS consent order detailed over USD 17.7 billion in USD transactions processed for Latvia's ABLV Bank between 2010 and 2014, with 479 flagged high-risk-party payments in the reviewed sample. Read together, the two findings support an assessment that sanctions-compliance risk is currently concentrated at the point where Finland's payment system connects to the rest of the world: its correspondent-banking corridor. #### Other Developments The EU's PSD3/PSR reform package has moved well past the 'pending' framing used in earlier assessments. Provisional political agreement was reached on 27 November 2025, the Council published final compromise texts on 23 April 2026, and Official Journal publication is expected in the third quarter of 2026, with the Payment Services Regulation applying directly around eighteen months after entry into force and the directive requiring an eighteen-month national transposition window, putting application at roughly 2027-2028. Finland continues to apply its PSD2/EMD2-based Payment Institutions Act (297/2010) and Payment Services Act (290/2010) until the new framework lands, with FIN-FSA acting as the single competent authority for both payment-institution/EMI licensing and MiCA crypto-asset-service-provider authorisation. The EU Instant Payments Regulation's compliance calendar is now clearer: euro-area banks had to receive instant credit transfers from 9 January 2025 and send them from 9 October 2025, while payment institutions and e-money institutions face receiving and sending deadlines of 9 January 2027 and 9 July 2027 respectively, and Verification of Payee already applies to every payment service provider, including PIs and EMIs, from 9 October 2025 rather than being deferred to 2027. On the stablecoin front, Finland's own six-month MiCA transition period ended 30 June 2025 - one of the shortest in the EU - and FIN-FSA-licensed EMI Paxos Issuance Europe Oy used the resulting clean regulatory runway to launch USDG, a MiCA-supervised USD-denominated stablecoin, across the EEA in July 2025, one of the first fully MiCA-regulated USD stablecoins in the bloc. On the product-innovation side, account-to-account payments reached a 33% share of Finnish e-commerce transaction value in 2023, nearly double the roughly 18% European average, while the Bank of Finland's payments unit examines how a prospective ECB digital euro would sit alongside Finland's own instant-payment rail. Separately, Finland's new Gambling Act, in force from January 2026, bans affiliate and influencer promotion of gambling for licensed and unlicensed operators alike and hands the incoming Finnish Supervisory Agency and National Police Board power to block the payments and websites of unlicensed operators, formalising a payment-blocking enforcement tool merchants and acquirers have used since 2023. Underpinning all of this, DORA has applied in Finland since 17 January 2025, with FIN-FSA supervising ICT-risk and operational-resilience obligations - including four-hour incident-classification reporting and triennial resilience testing - across banks, insurers, investment firms, payment institutions, EMIs and crypto-asset service providers regardless of size. #### Cross-Monitor Connections Two threads from this cycle are cross-referenced to the Financial Intelligence Monitor rather than analysed here as illicit-finance matters in their own right. First, Nordea's correspondent-banking AML control failures and FIN-FSA's sanctions-monitoring gap finding for Finnish PSPs carry illicit-finance and sanctions-evasion significance beyond this monitor's payments-context scope. Second, the MiCA CASP anti-money-laundering framework and the EU Transfer of Funds Regulation's extension of travel-rule obligations to crypto-asset transfers of any value carry surveillance implications that sit outside this monitor's stablecoin-as-payment-instrument lens. #### Outlook The near-term calendar is dominated by three dates: Official Journal publication of PSD3/PSR expected in the third quarter of 2026, the Instant Payments Regulation's payment-institution and e-money-institution deadlines of 9 January 2027 (receiving) and 9 July 2027 (sending), and the Gambling Act's licensing regime taking effect around the first quarter of 2027. Further out, Finland's fifth FATF Mutual Evaluation is anticipated around the first quarter of 2027, giving the February 2026 sanctions-monitoring gap finding added weight as a pre-evaluation readiness signal for FIN-FSA and the PSPs it supervises. trust tier: ai_unverified _Standing brief, as of 4 July 2026._ #### Regulatory Status Finland operates a standard, actively supervised EEA payments regime: FIN-FSA licenses and supervises payment institutions, e-money institutions and credit institutions under the Act on Payment Institutions (297/2010) and the Payment Services Act (290/2010), and doubles as the single gatekeeper for MiCA crypto-asset-service-provider authorisation. That baseline sits alongside an escalating financial-crime risk picture: FIN-FSA's February 2026 sanctions risk-assessment update found payment service providers have the most room for improvement in complying with sanctions regulations and national freezing orders. That gap builds on the 2024 NYDFS settlement that fined Nordea Bank Abp USD 35 million for correspondent-banking AML failures tied to ABLV Bank and Luminor. On the commercial and product frontier, account-to-account payments already account for a 33% share of Finnish e-commerce transaction value, and FIN-FSA-licensed EMI Paxos Issuance Europe Oy has launched USDG, one of the EU's first fully MiCA-regulated USD stablecoins. #### Outlook Finland's regulatory trajectory is tightening across licensing, instant payments and financial-crime compliance simultaneously: expect the PSD3/PSR Official Journal publication in Q3 2026, the Instant Payments Regulation's 2027 PI/EMI deadlines, and continued FIN-FSA follow-up on sanctions-monitoring gaps to dominate the compliance calendar into Finland's anticipated 2027 FATF Mutual Evaluation. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access moved Confirmed confirmed 2026-07-04 Finland regulates payment institutions and e-money institutions under PSD2/EMD2-derived national law (Act 898/2017, Act 890/2017), supervised by FIN-FSA. PSD3/PSR final texts were agreed at EU level in 2026 (ECON approval 5 May 2026) and will apply on a 21-month clock from Official Journal publication, landing effective application around Q1-Q2 2028; no FI-specific transposition text was located this cycle. Movement — CHANGED CRD6-driven banking M&A notification regime entered into force 1 Oct 2026_New EU-driven instrument entered into force this cycle._ Horizon · 2026-Q3 (±half_year) PSD3/PSR Official Journal publication_in_force_pending · TT3_ Horizon · 2027-Q4 (±multi_year) PSR direct application / PSD3 national transposition deadline_in_force_pending · TT3_ Standing sub-brief · as of 4 July 2026 250 words · last cycle 2026-10-18 #### Licensing, Authorisation & Market Access Finland runs the standard EEA licensing regime for payment services: FIN-FSA authorises and supervises payment institutions and e-money institutions under the Act on Payment Institutions (297/2010) and the Payment Services Act (290/2010), covering both provision of payment services and issuance of e-money. Beneath full authorisation, light-touch registration routes remain available - full PI authorisation is only required once average monthly transaction turnover exceeds EUR 3 million, and full EMI authorisation only once issued e-money exceeds EUR 5 million. FIN-FSA also doubles as Finland's single gatekeeper for MiCA crypto-asset-service-provider authorisation, giving one authority oversight of both the payments and crypto-asset licensing perimeters. The most consequential development this cycle is procedural rather than substantive: the EU's PSD3/PSR reform package, once carried in prior assessments as merely 'pending', has in fact reached provisional political agreement (27 November 2025) and final Council compromise texts (23 April 2026), with Official Journal publication expected in Q3 2026. Direct application of the Payment Services Regulation follows roughly eighteen months after entry into force, while the accompanying directive requires an eighteen-month national transposition window - pointing to real-world application in Finland around 2027-2028. Until then, Finland continues to operate under its existing PSD2/EMD2 transposition. #### Outlook Watch the Official Journal publication date in Q3 2026 as the trigger for Finland's PSD3/PSR transposition clock; expect FIN-FSA guidance on the light-registration thresholds to be revisited once national implementing measures are drafted, and expect continued convergence between payment-institution and MiCA CASP supervision under a single FIN-FSA mandate. Periodic update · new data 2026-10-18 #### Licensing, Authorisation & Market Access Finland's banking M&A and structural-change supervisory regime tightened materially on 1 October 2026 with the entry into force of a new chapter of the Act on Credit Institutions implementing CRD6. The new chapter introduces advance written notification requirements to FIN-FSA for credit institutions ahead of material asset or liability transfers reaching a 10% balance-sheet-value threshold, or 15% where the transfer is intra-group, as well as material-holding acquisitions and mergers or demergers of credit institutions. These transactions are now subject to FIN-FSA's own assessment and approval process rather than proceeding on a notification-only basis. This is a market-access and structural-change development specifically for the bank-PSP model: a bank considering a material transfer of assets, a material-holding acquisition, or a merger or demerger must now build an advance notification and FIN-FSA approval step into its transaction timeline. The obligation does not extend to non-bank payment institutions or e-money institutions, whose authorisation and structural-change framework sits outside the Act on Credit Institutions. Separately, FIN-FSA published updated principles on 1 October 2026 for determining the size of penalty payments and administrative fines across all supervised sectors, giving more explicit weight to early and comprehensive cooperation by a responsible party; while not specific to licensing or market access, this shapes the consequences of any future non-compliance with the new notification regime. #### Outlook The practical operation of the new CRD6 notification and approval process has not yet been tested against an actual transaction, so the pace and rigour of FIN-FSA's assessment process remains to be observed. A bank-PSP planning a material asset transfer, holding acquisition, merger, or demerger should expect the advance notification and approval step to now form part of the transaction timeline from 1 October 2026 onward. **3 earlier distinct update(s)** Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access Finland's payment-services licensing basis remains the Payment Services Act, implemented via Acts 898/2017 and 890/2017, transposing PSD2 and in force mainly from 13 January 2018; this continues to be the operative legal basis for FIN-FSA-supervised payment and e-money institutions in Finland. The material development this cycle sits at the EU level: PSD3 and the Payment Services Regulation reached final-text agreement among EU Parliament, Council, and Commission negotiators on 27 November 2025, with the European Parliament's ECON committee approving the agreed texts on 5 May 2026. Plenary vote and Official Journal publication are expected mid-to-late 2026, which will start a 21-month application clock currently projected to land effective application around Q1-Q2 2028. No Finland-specific transposition text for PSD3/PSR has yet been located, so this remains tracked at the supranational level pending national implementing measures. A concrete obligation already operative ahead of the full PSD3/PSR timeline is the IBAN-name Verification of Payee check, mandatory for SEPA Instant transfers since 9 October 2025 under the Instant Payments Regulation. PSD3/PSR is set to extend this check to all transfer rails, not just SEPA Instant, once it enters into application, meaning Finnish payment service providers already compliant on the SEPA Instant rail have a partial head start on the wider obligation. #### Outlook The PSD3/PSR plenary vote and Official Journal publication timing, expected mid-to-late 2026, will fix the start date of the 21-month application clock and therefore the effective date of the expanded Verification of Payee mandate across all transfer rails. Whether and how Finland transposes or otherwise implements PSD3/PSR domestically once adopted is the key item to track into subsequent cycles. Periodic update · new data 2026-09-14 #### Licensing, Authorisation & Market Access Finland's payment-institution licensing regime is administered by FIN-FSA under a threshold-based registration and authorisation structure, with the average threshold for small-payment-institution registration set at EUR 3,000,000 in monthly transactions. Institutions handling transaction volumes below this threshold may operate under the lighter small-payment-institution registration category, while those above it require full payment-institution authorisation, carrying a more substantial prudential and conduct compliance burden. What distinguishes Finland's regime this cycle is evidence of active supervisory enforcement behind this threshold structure: FIN-FSA has withdrawn payment-institution registrations specifically for sanctions-screening failures, demonstrating that the registration and authorisation framework is not a passive formality but is backed by genuine ongoing supervisory scrutiny. This finding is held at probable confidence and is analytically significant because it indicates a more rigorous supervisory posture than a purely threshold-based light-touch registration regime would suggest on its face — the existence of a registration category does not by itself indicate how actively that category is policed, and Finland's withdrawal history supplies exactly that missing enforcement-posture evidence. The bank-versus-non-bank distinction is directly relevant here: small payment institutions and payment institutions (the non-bank PI/EMI population) face this threshold-and-withdrawal-risk regime directly, whereas banks operate under a separate prudential authorisation track. For a non-bank payment institution or EMI considering Finnish market access, the take-away is that the registration threshold itself is only part of the compliance picture; ongoing sanctions-screening adequacy is evidently a live supervisory priority that can result in registration withdrawal if found deficient. #### Outlook The item to watch is whether further registration withdrawals occur in coming cycles, which would confirm this cycle's finding as a sustained supervisory pattern rather than an isolated enforcement episode, and would further clarify the practical compliance bar non-bank payment institutions must clear to retain FIN-FSA authorisation. Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access Finland's payment and crypto-asset licensing landscape operates across two distinct regulatory tracks that increasingly overlap in practice. FIN-FSA serves as the primary regulator authorising and supervising all crypto-asset service providers operating in Finland under the Markets in Crypto-Assets Regulation, a role that layers a new MiCA-based authorisation perimeter on top of Finland's existing PSD2-derived payment-licensing framework. For firms operating in both payments and crypto-asset services, this means navigating two parallel, FIN-FSA-administered authorisation regimes rather than a single unified licence. At the lower end of the market, Finland's Small Payment Institution registration route continues to offer a lighter-touch entry path for domestic payment-services providers. Registration under this route carries a EUR 3 million monthly transaction-volume cap, restricts activity to domestic payment services, and requires compliance with an anti-money-laundering framework distinct from the fuller obligations attached to full payment institution or e-money institution authorisation. This bank/non-bank distinction is structurally significant: the SPI route is available only to non-bank entities operating below the volume threshold, meaning it functions as a genuine on-ramp for smaller fintech entrants rather than a route available to banks or larger payment institutions. #### Outlook Watch for how the forthcoming PSD3/PSR transition interacts with Finland's existing SPI registration tier once the new regime's twenty-one-month transposition period begins, since PSD3 is expected to revise authorisation categories at EU level. Watch also for growth in FIN-FSA's MiCA-authorised CASP population specific to Finland, which was not separately confirmed this cycle against the EU-wide total of 199 authorised entities across 23 countries. **Sources and findings (6)** 1. T1 [https://www.finanssivalvonta.fi/en/financial-market-participants/banks/authorisations-registrations-and-notifications/payment-service-providers/](https://www.finanssivalvonta.fi/en/financial-market-participants/banks/authorisations-registrations-and-notifications/payment-service-providers/) retrieved 2026-07-04 2. T1 [https://www.finanssivalvonta.fi/en/financial-market-participants/banks/authorisations-registrations-and-notifications/payment-service-providers/](https://www.finanssivalvonta.fi/en/financial-market-participants/banks/authorisations-registrations-and-notifications/payment-service-providers/) retrieved 2026-07-04 3. T3 [https://www.nordiclaw.fi/en/news/how-to-be-an-emi](https://www.nordiclaw.fi/en/news/how-to-be-an-emi) retrieved 2026-07-04 4. T3 [https://practiceguides.chambers.com/practice-guides/fintech-2025/finland](https://practiceguides.chambers.com/practice-guides/fintech-2025/finland) retrieved 2026-07-04 5. T3 [https://globallawexperts.com/how-to-be-a-payment-institution-in-finland/](https://globallawexperts.com/how-to-be-a-payment-institution-in-finland/) retrieved 2026-07-04 6. T1 [https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/finland](https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/finland) retrieved 2026-07-04 ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-07-04 FIN-FSA and Consumer Ombudsman jointly police conduct/safeguarding/promotions; IPR VoP applies from Oct 2025 to all PSPs, PI/EMI instant-payment deadlines fall Jan/Jul 2027. Horizon · 2027-01-09 (±quarter) Instant Payments Regulation - PI/EMI receiving deadline_in_force_pending · TT3_ Horizon · 2027-07-09 (±quarter) Instant Payments Regulation - PI/EMI sending deadline_in_force_pending · TT3_ Horizon · 2027-Q1 (±half_year) Finland Gambling Act licensing regime commencement_in_force_pending · TT3_ Standing sub-brief · as of 4 July 2026 181 words · last cycle 2026-08-05 #### Conduct, Safeguarding & Financial Promotions FIN-FSA supervises all PSD2-regulated payment service providers in Finland, including third-party providers, which must be authorised or registered before commencing operations and appear on FIN-FSA's public register. The Instant Payments Regulation's compliance calendar carries corrected detail this cycle: payment institutions and e-money institutions must be able to receive instant euro credit transfers by 9 January 2027 and send them by 9 July 2027, and - contrary to an earlier reading - Verification of Payee already binds every payment service provider, including PIs and EMIs, from 9 October 2025. On the financial-promotions side, Finland's new Gambling Act - in force from January 2026 - bans affiliate and influencer promotion of gambling for licensed and unlicensed operators alike and gives the incoming Finnish Supervisory Agency and National Police Board power to block payments and websites of unlicensed operators. #### Outlook Expect FIN-FSA and industry guidance to sharpen around the 2027 instant-payment deadlines for PIs and EMIs well before they bite, and expect continued financial-promotion enforcement activity as the new Gambling Act's payment- and website-blocking powers come online in 2026-2027. Periodic update · new data 2026-08-11 #### Conduct, Safeguarding & Financial Promotions The PSD3/PSR legislative package reached final compromise text, approved by national representatives on 22 April 2026, with formal publication expected in the third quarter of 2026 and a twenty-one-month transition period to follow for member states, including Finland. The Payment Services Regulation will repeal and replace PSD2 and the second E-Money Directive across the European Economic Area, consolidating and updating the conduct and safeguarding framework that currently governs Finnish payment service providers and e-money institutions. The single most consequential conduct-side provision is the new payee-name and IBAN verification mandate. Under the PSR, payment service providers across the EU will be required to verify that the stated payee name matches the account holder before a transfer is authorised; where a mismatch is detected, the payer must be warned before the transfer proceeds, and liability for a failure to notify the payer of a mismatch shifts to the payer's own provider. This is, in effect, an EU-wide confirmation-of-payee mandate with a built-in liability-allocation mechanism, applying uniformly rather than through fragmented national implementation, and it will require Finnish banks and payment institutions to build or adapt payee-verification infrastructure ahead of the transposition deadline. #### Outlook Watch for the formal publication of the PSD3/PSR final text, which will fix the exact start date of the twenty-one-month transition period for Finnish implementation. Watch also for any Finland-specific transposition guidance from national authorities addressing how the payee-verification and liability-shift provisions will interact with existing Finnish fraud-prevention practice. **Sources and findings (5)** 1. T1 [https://www.finanssivalvonta.fi/en/Consumer-protection/payment-services/psd2--second-payment-services-directive/](https://www.finanssivalvonta.fi/en/Consumer-protection/payment-services/psd2--second-payment-services-directive/) retrieved 2026-07-04 2. T3 [https://legasset.com/ready-made-emi-license-finland-for-sale/](https://legasset.com/ready-made-emi-license-finland-for-sale/) retrieved 2026-07-04 3. T1 [https://www.kkv.fi/en/consumer-affairs/consumer-ombudsman/](https://www.kkv.fi/en/consumer-affairs/consumer-ombudsman/) retrieved 2026-07-04 4. T3 [https://globallawexperts.com/how-to-be-a-payment-institution-in-finland/](https://globallawexperts.com/how-to-be-a-payment-institution-in-finland/) retrieved 2026-07-04 5. T3 [https://www.businessofigaming.com/finland-gambling-reform/](https://www.businessofigaming.com/finland-gambling-reform/) retrieved 2026-07-04 ### W2 Stablecoins & Digital Money Confirmed confirmed 2026-07-04 Finland's MiCA transition (six months, ended 30 Jun 2025) is among the EU's shortest; FIN-FSA authorises EMT/ART issuance and CASP activity; Paxos Issuance Europe Oy issues MiCA-compliant USDG. Standing sub-brief · as of 4 July 2026 219 words · last cycle 2026-07-04 #### Stablecoins & Digital Money Finland's national MiCA transition period ran just six months and ended 30 June 2025, one of the shortest in the EU alongside the Netherlands, Latvia, Hungary and Slovenia, well ahead of the EU-wide maximum transition date of 1 July 2026 available to other member states; since 30 June 2025, only MiCA-authorised firms may issue e-money tokens or asset-referenced tokens or provide crypto-asset services in Finland. FIN-FSA-licensed EMI Paxos Issuance Europe Oy (also styled 'Paxos Issuance Europe' in some source variants) used that early-mover position to launch USDG in the EU in July 2025 under MiCA e-money-token supervision, passporting the USD-denominated stablecoin EEA-wide as among the first fully MiCA-regulated USD stablecoins in the bloc. More broadly, Finnish MiCA issuers must meet strict prudential terms: e-money-token holders retain a statutory par-value redemption right backed by e-money-style safeguarding (segregation or insurance/guarantee), while asset-referenced-token issuers must hold a segregated high-quality liquid reserve, publish monthly reserve reports and secure independent audits at least every six months. This positions Finland as an early and credible venue for MiCA-supervised stablecoin issuance rather than merely a licensing way-station. #### Outlook Watch for additional EMI-licensed issuers to follow Paxos's path now that Finland's MiCA transition has fully closed, and expect FIN-FSA to publish further guidance on EMT/ART reserve-reporting and audit cadence as the regime matures. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://www.plasma.to/learn/tools/stablecoin-regulation-map/finland](https://www.plasma.to/learn/tools/stablecoin-regulation-map/finland) retrieved 2026-07-04 2. T1 [https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/finland](https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/finland) retrieved 2026-07-04 3. T3 [https://www.plasma.to/learn/tools/stablecoin-regulation-map/finland](https://www.plasma.to/learn/tools/stablecoin-regulation-map/finland) retrieved 2026-07-04 4. T3 [https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/finland](https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/finland) retrieved 2026-07-04 5. T3 [https://www.lightspark.com/knowledge/is-crypto-legal-in-finland](https://www.lightspark.com/knowledge/is-crypto-legal-in-finland) retrieved 2026-07-04 ### W3 Operational Resilience & Critical Infrastructure Confirmed confirmed 2026-07-04 Finland is in the euro-area SEPA Instant Credit Transfer (SCT Inst) / Instant Payments Regulation (EU 2024/886) implementation phase: mandatory receipt of instant credit transfers since 9 January 2025, mandatory sending since 9 October 2025, and mandatory free Verification-of-Payee checks from the same October 2025 date. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/finland/) Standing sub-brief · as of 4 July 2026 112 words · last cycle 2026-09-14 #### Operational Resilience & Critical Infrastructure DORA has applied in Finland since 17 January 2025, with FIN-FSA acting as the competent authority for DORA supervision of banks, insurers, investment firms, payment institutions, EMIs and crypto-asset service providers regardless of entity size. The regime requires major-incident classification and reporting within four hours of classification (24 hours from detection), resilience testing including penetration testing every three years for significant entities, and a register of critical ICT third-party providers, with microenterprises subject to a simplified framework though incident-reporting duties still apply. #### Outlook Expect FIN-FSA to continue folding AI Act market-surveillance preparation into its existing DORA supervisory programme, with resilience-testing cycles and critical-ICT-provider registers maturing through 2026. Periodic update · new data 2026-09-14 #### Operational Resilience & Critical Infrastructure Finland's payment service providers are now operating under the fully mandatory regime of Regulation (EU) 2024/886, the Instant Payments Regulation. Mandatory receipt of instant credit transfers has applied since 9 January 2025, and the second and more operationally demanding phase — mandatory sending of instant credit transfers together with free Verification-of-Payee checks — has applied since 9 October 2025. This is a confirmed finding, and it represents the completion of a phased EU-wide operational-resilience mandate rather than a discretionary national implementation choice. The practical operational consequence for Finnish payment service providers is that instant payment infrastructure is no longer an optional value-added service but a mandatory baseline capability, with the free Verification-of-Payee requirement adding a specific anti-fraud operational obligation on top of the underlying instant-transfer-processing requirement. Because this regulation applies uniformly across the euro area, Finnish PSPs face the same operational-resilience baseline as their counterparts elsewhere in the EEA, removing any comparative advantage or disadvantage that might otherwise arise from differential national implementation timelines. This finding sits within the module's critical-infrastructure framing because instant-payment processing capability, once mandatory, becomes part of the baseline infrastructure a Finnish PSP must maintain continuously rather than a discretionary product feature; any operational failure in meeting the mandatory sending or Verification-of-Payee obligations would itself become a conduct and resilience issue under the broader regulatory framework. #### Outlook With both phases of the Instant Payments Regulation's mandatory requirements now in force, the item to watch shifts from implementation-timeline compliance to operational-performance monitoring: whether Finnish PSPs are meeting the Verification-of-Payee and instant-sending obligations reliably at scale, which was not independently assessed this cycle. **Sources and findings (5)** 1. T1 [https://eurocomply.app/regulations/dora/finland](https://eurocomply.app/regulations/dora/finland) retrieved 2026-07-04 2. T2 [https://eurocomply.app/regulations/dora/finland](https://eurocomply.app/regulations/dora/finland) retrieved 2026-07-04 3. T3 [https://practiceguides.chambers.com/practice-guides/fintech-2025/finland](https://practiceguides.chambers.com/practice-guides/fintech-2025/finland) retrieved 2026-07-04 4. T1 [https://www.finanssivalvonta.fi/en/publications-and-press-releases/annual-reports/annual-report-2025/supervision/](https://www.finanssivalvonta.fi/en/publications-and-press-releases/annual-reports/annual-report-2025/supervision/) retrieved 2026-07-04 5. T1 [https://www.finanssivalvonta.fi/en/](https://www.finanssivalvonta.fi/en/) retrieved 2026-07-04 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-04 Card-scheme compliance runs on global PCI DSS baseline layered with IPR scheme-level obligations; no bespoke FI interchange/surcharging statute identified. Standing sub-brief · as of 4 July 2026 134 words · last cycle 2026-07-04 #### Scheme & Network Compliance PCI DSS defines the baseline technical and operational security requirements for any entity that stores, processes or transmits card data, applying to Finnish merchants, acquirers, processors and issuers on the Visa and Mastercard schemes. Layered on top of that scheme baseline, the Instant Payments Regulation made instant euro credit transfers and Verification of Payee mandatory for euro-area banks from 9 October 2025, with Verification of Payee applying to all payment service providers including PIs and EMIs from the same date, reshaping scheme-level technical and security obligations ahead of the 9 January 2027 and 9 July 2027 PI/EMI compliance deadlines. #### Outlook Expect scheme-level technical specifications to keep tightening as Finnish PIs and EMIs prepare for the 2027 Instant Payments Regulation deadlines layered on top of the existing PCI DSS card-data baseline. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T1 [https://www.pcisecuritystandards.org/standards/pci-dss/](https://www.pcisecuritystandards.org/standards/pci-dss/) retrieved 2026-07-04 2. T2 [https://www.visa.fi/fi_FI/partner-with-us/pci-dss-compliance-information.html](https://www.visa.fi/fi_FI/partner-with-us/pci-dss-compliance-information.html) retrieved 2026-07-04 3. T3 [https://legasset.com/ready-made-emi-license-finland-for-sale/](https://legasset.com/ready-made-emi-license-finland-for-sale/) retrieved 2026-07-04 ### W5 Payment Corridor Dynamics Confirmed confirmed 2026-07-04 Principal corridors run through SEPA/SEPA Instant and the Siirto national instant-payment rail, supplemented by P27 Nordic integration and CESOP reporting. Standing sub-brief · as of 4 July 2026 88 words · last cycle 2026-09-28 #### Payment Corridor Dynamics Finland is a full SEPA member, eliminating the distinction between national and cross-border euro payments across the 36-market SEPA zone. In 2025, responsibility for implementing the Finnish Instant Payments Scheme Rulebook - completed in 2024 and aligned to Eurosystem and EU standards - was transferred from the Bank of Finland-chaired Payments Council to Siirto Brand Oy. #### Outlook Watch Siirto Brand Oy's rollout of the 2024 Instant Payments Scheme Rulebook and its interaction with the EU-wide Instant Payments Regulation deadlines as the main near-term corridor development. Periodic update · new data 2026-09-28 #### Payment Corridor Dynamics Finland's instant-payments corridor runs on SEPA Instant Credit Transfer alongside the domestic Siirto product, with the two systems designed to coexist rather than compete directly. SEPA Instant carries a general scheme maximum of EUR 100,000 as of 1 July 2020, though Finnish banks have agreed to remove the upper limit specifically for domestic transfers, a national variance more permissive than the scheme-wide parameter. The Instant Payments Regulation has driven two concrete compliance milestones that are now both in effect: all payment service providers offering SEPA payments were required to be able to receive instant transfers from January 2025, and to send them from October 2025. Siirto, operated by Automatia, is positioned to function alongside SEPA Instant rather than to replace it, and send-side interoperability between Siirto and the wider Finnish banking system is still described as evolving rather than complete. This dual-rail structure — a domestic mobile-payment product running in parallel with the EU-wide SEPA Instant scheme, now fully subject to IPR send/receive mandates — is the defining corridor-dynamics feature of the Finnish market this cycle. #### Outlook The completion of Finnish banks' removal of the domestic SEPA Instant transfer cap, and the continued evolution of Siirto's send-side interoperability across all Finnish banks, are the two concrete corridor-dynamics developments to track. The IBAN-name Verification of Payee check already mandatory on the SEPA Instant rail is expected to extend to all transfer rails once PSD3/PSR takes effect, which will be a further corridor-level change to monitor. **1 earlier distinct update(s)** Periodic update · new data 2026-08-11 #### Payment Corridor Dynamics The EU Instant Payments Regulation's fee-parity provisions are now in effect, requiring payment service providers that offer standard credit transfers to also offer instant credit transfers at the same fee as the standard service. This removes the pricing differential that has, in some EU markets, allowed instant transfers to be marketed as a premium-priced service distinct from standard transfers. For Finland specifically, the practical adjustment is narrower than in some other EU markets, because Finnish domestic payment rails already operate on a twenty-four-hour, real-time basis under existing SEPA and PSD2 infrastructure; the fee-parity mandate therefore principally affects pricing structure rather than requiring new real-time settlement capability to be built from scratch. #### Outlook Watch for whether Finnish payment service providers adjust pricing structures to reflect full fee parity across all credit-transfer products, and for any divergence between domestic-corridor pricing and cross-border SEPA instant-transfer pricing now that the parity mandate applies EU-wide. **Sources and findings (5)** 1. T2 [https://www.trade.gov/country-commercial-guides/finland-trade-financing](https://www.trade.gov/country-commercial-guides/finland-trade-financing) retrieved 2026-07-04 2. T1 [https://www.suomenpankki.fi/en/news-and-topical/press-releases-and-news/releases/2025/responsibility-for-developing-a-finnish-instant-payment-solution-is-to-be-transferred-from-the-payments-council-to-siirto-brand-oy/](https://www.suomenpankki.fi/en/news-and-topical/press-releases-and-news/releases/2025/responsibility-for-developing-a-finnish-instant-payment-solution-is-to-be-transferred-from-the-payments-council-to-siirto-brand-oy/) retrieved 2026-07-04 3. T3 [https://www.transfi.com/blog/finlands-payment-rails-sepa-siirto-and-the-digital-first-economy](https://www.transfi.com/blog/finlands-payment-rails-sepa-siirto-and-the-digital-first-economy) retrieved 2026-07-04 4. T3 [https://practiceguides.chambers.com/practice-guides/fintech-2025/finland](https://practiceguides.chambers.com/practice-guides/fintech-2025/finland) retrieved 2026-07-04 5. T3 [https://www.mckinsey.com/industries/financial-services/our-insights/nordic-payments-where-collaboration-and-competition-lead-to-innovation](https://www.mckinsey.com/industries/financial-services/our-insights/nordic-payments-where-collaboration-and-competition-lead-to-innovation) retrieved 2026-07-04 ### W6 Industry Structure & Commercial Confirmed confirmed 2026-07-04 Market remains bank-dominated (OP, Nordea, Danske) with shared-utility infrastructure and consolidating bank-owned wallet infrastructure. Standing sub-brief · as of 4 July 2026 101 words · last cycle 2026-07-04 #### Industry Structure & Commercial Dynamics Finland's payments and banking market is dominated by three major deposit-bank groups - OP Financial Group, Nordea and Danske Bank - alongside smaller domestic players such as S-Pankki, Aktia and Saastopankki, with 247 credit institutions operating in Finland in 2023. In 2021, Danske Bank, OP Financial Group and the Vipps banking consortium agreed to merge their mobile-payment apps MobilePay, Vipps and Pivo into a combined Nordic digital wallet, the same year Nets-owned Paytrail acquired Checkout Finland. #### Outlook Expect continued bank-led consolidation of shared payments infrastructure (wallets, acquiring) rather than material erosion of the three-group deposit-bank dominance. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T2 [https://www.trade.gov/country-commercial-guides/finland-trade-financing](https://www.trade.gov/country-commercial-guides/finland-trade-financing) retrieved 2026-07-04 2. T1 [https://www.suomenpankki.fi/en/news-and-topical/press-releases-and-news/releases/2025/responsibility-for-developing-a-finnish-instant-payment-solution-is-to-be-transferred-from-the-payments-council-to-siirto-brand-oy/](https://www.suomenpankki.fi/en/news-and-topical/press-releases-and-news/releases/2025/responsibility-for-developing-a-finnish-instant-payment-solution-is-to-be-transferred-from-the-payments-council-to-siirto-brand-oy/) retrieved 2026-07-04 3. T3 [https://www.mckinsey.com/industries/financial-services/our-insights/nordic-payments-where-collaboration-and-competition-lead-to-innovation](https://www.mckinsey.com/industries/financial-services/our-insights/nordic-payments-where-collaboration-and-competition-lead-to-innovation) retrieved 2026-07-04 4. T3 [https://www.kenresearch.com/finland-payments-market](https://www.kenresearch.com/finland-payments-market) retrieved 2026-07-04 5. T3 [https://www.researchandmarkets.com/reports/5305012/finland-buy-now-pay-later-business-and](https://www.researchandmarkets.com/reports/5305012/finland-buy-now-pay-later-business-and) retrieved 2026-07-04 ### W7 Legal & Litigation limited signal Confirmed confirmed 2026-07-04 FIN-FSA maintains active AML enforcement record; 2024 NYDFS $35m Nordea settlement is the most consequential payments-adjacent litigation. Standing sub-brief · as of 4 July 2026 102 words · last cycle 2026-10-18 #### Legal & Litigation In August 2024, NYDFS fined Helsinki-headquartered Nordea Bank Abp USD 35 million for BSA/AML compliance failures and inadequate due diligence over high-risk correspondent-banking relationships including ABLV Bank and Luminor. FIN-FSA has its own enforcement record too: it withdrew Nada express osk's payment-institution registration in January 2023 and imposed a EUR 10,000 penalty on Halgan Services Oy in April 2022 for AML compliance deficiencies, part of a broader pattern of enforcement against money-remittance and payment firms. #### Outlook Expect continued FIN-FSA AML enforcement activity against smaller payment/e-money firms, with the 2024 Nordea settlement remaining the reference point for correspondent-banking litigation exposure. Periodic update · new data 2026-10-18 #### Legal & Litigation The Helsinki Administrative Court accepted an appeal by Alexandria Group Oyj and annulled a EUR 1,000,000 joint penalty that FIN-FSA had imposed in June 2025, finding in the firm's favour; FIN-FSA was ordered to pay EUR 30,000 toward Alexandria Group Oyj's legal costs. The ruling is not yet final. The underlying penalty concerned an alleged failure to obtain legally required client information before making investment recommendations, a suitability and investor-protection matter rather than a payments-sector finding; Alexandria Group Oyj is a non-payments investment firm. The relevance of this matter to the payments sector is limited to what it signals about FIN-FSA's general enforcement posture and its exposure when a penalty decision is appealed: a court has found against the regulator on a significant penalty and ordered it to bear a portion of the appellant's costs, while the matter remains open pending finality. This sits alongside FIN-FSA's separate, cross-sector update to its penalty-determination principles, published 1 October 2026, which gives greater explicit weight to early and comprehensive cooperation by a responsible party, a procedural change that would apply equally to any future payments-sector enforcement matter. #### Outlook Whether the Alexandria Group Oyj ruling becomes final, and whether FIN-FSA appeals further, remains to be observed. The episode is a data point on FIN-FSA's enforcement exposure on appeal rather than a payments-sector-specific development in its own right. **Sources and findings (6)** 1. T1 [https://www.finanssivalvonta.fi/en/financial-market-participants/banks/prevention-of-money-laundering-and-terrorist-financing/current-provisions/](https://www.finanssivalvonta.fi/en/financial-market-participants/banks/prevention-of-money-laundering-and-terrorist-financing/current-provisions/) retrieved 2026-07-04 2. T1 [https://www.finanssivalvonta.fi/en/financial-market-participants/banks/prevention-of-money-laundering-and-terrorist-financing/current-provisions/](https://www.finanssivalvonta.fi/en/financial-market-participants/banks/prevention-of-money-laundering-and-terrorist-financing/current-provisions/) retrieved 2026-07-04 3. T3 [https://practiceguides.chambers.com/practice-guides/fintech-2025/finland](https://practiceguides.chambers.com/practice-guides/fintech-2025/finland) retrieved 2026-07-04 4. T1 [https://www.dfs.ny.gov/reports_and_publications/press_releases/pr20240827](https://www.dfs.ny.gov/reports_and_publications/press_releases/pr20240827) retrieved 2026-07-04 5. T1 [https://www.finanssivalvonta.fi/en/publications-and-press-releases/annual-reports/annual-report-2025/supervision/](https://www.finanssivalvonta.fi/en/publications-and-press-releases/annual-reports/annual-report-2025/supervision/) retrieved 2026-07-04 6. T1 [https://www.finanssivalvonta.fi/en/](https://www.finanssivalvonta.fi/en/) retrieved 2026-07-04 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-04 Merchant acquiring licensed as a payment service under PIA; incoming gambling regime formalises payment-blocking as enforcement tool. Standing sub-brief · as of 4 July 2026 101 words · last cycle 2026-07-04 #### Merchant Acquiring & Risk Acquiring of payment transactions is one of the payment services enumerated under the Act on Payment Institutions (297/2010); merchant-acquiring activity requires FIN-FSA payment-institution or credit-institution authorisation rather than a bespoke acquiring statute. Finland's incoming gambling licensing regime formalises payment-blocking as a merchant- and acquirer-side enforcement tool against unlicensed operators - a mechanism already in use since 2023 and now vested in the new Finnish Supervisory Agency and National Police Board. #### Outlook Expect payment-blocking to become a standard acquirer-side compliance expectation once the Gambling Act's licensing regime takes effect, extending a tool already in informal use since 2023. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T1 [https://www.finanssivalvonta.fi/en/financial-market-participants/banks/authorisations-registrations-and-notifications/payment-service-providers/](https://www.finanssivalvonta.fi/en/financial-market-participants/banks/authorisations-registrations-and-notifications/payment-service-providers/) retrieved 2026-07-04 2. T4 [https://durangomerchantservices.com/credit-card-processing-and-high-risk-merchant-accounts-in-finland/](https://durangomerchantservices.com/credit-card-processing-and-high-risk-merchant-accounts-in-finland/) retrieved 2026-07-04 3. T3 [https://zimpler.com/blog/igaming-regulation-in-finland-the-ultimate-guide/](https://zimpler.com/blog/igaming-regulation-in-finland-the-ultimate-guide/) retrieved 2026-07-04 ### W9 Product Innovation & Market Development Confirmed confirmed 2026-07-04 Bank of Finland-coordinated instant-payment rail development, prospective ECB digital-euro alignment, TIBER-FI testing and rapid A2A growth define the innovation frontier. Standing sub-brief · as of 4 July 2026 96 words · last cycle 2026-09-14 #### Product Innovation & Market Development Account-to-account, pay-by-bank payments reached a 33% share of e-commerce transaction value in Finland in 2023, against a roughly 18% European average, making it Finland's fastest-growing payment method. Meanwhile, the Bank of Finland's payments unit is examining the overlap and synergies between prospective ECB digital-euro issuance and Finland's own instant-payment rail development, positioning Siirto and national instant payments as a near-term complement to a future digital euro. #### Outlook Expect A2A/pay-by-bank adoption to keep climbing and the Bank of Finland's digital-euro/instant-payments study to shape how a future digital euro is positioned alongside Siirto. Periodic update · new data 2026-09-14 #### Product Innovation & Market Development Finland's new Gambling Act (10/2026) is constructing a distinct, licence-conditioned payments surface specifically for the newly-competitive gambling vertical ahead of its 1 July 2027 market opening. Licence applicants to Poliisihallitus (the National Police Board) must submit financial-stability documentation and AML-control frameworks as part of the licensing dossier, meaning the payments dimension of gambling-operator compliance is being gated at the point of licensing rather than left to post-entry supervision. This finding is held at probable confidence, reflecting the underlying Gambling Act's confirmed provisions but a still-developing evidentiary picture of exactly how the payments-specific compliance detail will be operationalised. This is a genuinely new product-access regulatory development distinct from a structural market-analysis trend (which would sit under industry-structure-and-commercial-dynamics) or a discrete commercial event such as an M&A deal or product launch (which would sit under commercial-intelligence-and-fintech): it is a thematic, regulation-driven reshaping of how payments access to the Finnish gambling vertical will be gated going forward. The financial-stability and AML-control documentation requirements together suggest that Finnish regulators are treating payments integrity as a first-order licensing criterion for the newly-competitive gambling market, rather than a secondary compliance matter addressed only after market entry. For payment service providers and payment-facilitation businesses considering involvement in Finland's newly-licensed gambling vertical, this represents a concrete new compliance surface to track: engagement with a Finnish gambling operator licensee will likely require visibility into that operator's own financial-stability and AML-control standing as established through the Poliisihallitus licensing process. #### Outlook The item to watch is the specific content of the financial-stability and AML-control documentation requirements as licences begin to be granted, expected by end-2026 ahead of the 1 July 2027 market opening, which would clarify the precise payments-compliance bar for the gambling vertical. **Sources and findings (5)** 1. T1 [https://www.suomenpankki.fi/en/news-and-topical/press-releases-and-news/releases/2025/responsibility-for-developing-a-finnish-instant-payment-solution-is-to-be-transferred-from-the-payments-council-to-siirto-brand-oy/](https://www.suomenpankki.fi/en/news-and-topical/press-releases-and-news/releases/2025/responsibility-for-developing-a-finnish-instant-payment-solution-is-to-be-transferred-from-the-payments-council-to-siirto-brand-oy/) retrieved 2026-07-04 2. T1 [https://www.centralbanking.com/central-banks/currency/digital-currencies/7963556/finlands-fintech-head-on-retail-cdbcs-versus-instant-payments](https://www.centralbanking.com/central-banks/currency/digital-currencies/7963556/finlands-fintech-head-on-retail-cdbcs-versus-instant-payments) retrieved 2026-07-04 3. T3 [https://editorialge.com/finland-banking-system-cbdc-exploration-2026/](https://editorialge.com/finland-banking-system-cbdc-exploration-2026/) retrieved 2026-07-04 4. T3 [https://mobileidworld.com/finnish-banks-op-financial-and-nordea-lead-digital-payment-market-transformation/](https://mobileidworld.com/finnish-banks-op-financial-and-nordea-lead-digital-payment-market-transformation/) retrieved 2026-07-04 5. T3 [https://noda.live/articles/payment-methods-in-finland](https://noda.live/articles/payment-methods-in-finland) retrieved 2026-07-04 ### W10 Consumer Protection & APP Fraud Confirmed confirmed 2026-07-04 Dispute resolution runs through FINE and Consumer Ombudsman; no UK-style APP-fraud reimbursement rule; FIN-FSA flags fraud as rising supervisory priority. Standing sub-brief · as of 4 July 2026 101 words · last cycle 2026-07-04 #### Consumer Protection & APP Fraud Finland has no UK-style mandatory APP-fraud reimbursement rule: banks must refund unauthorised payment transactions, with liability capped absent gross negligence, but are not required to refund authorised transfers where the customer was deceived into authorising the transaction. FIN-FSA observed increasing variations of scams during 2024 and issued more penalty payments than before, prompting it to flag payment fraud and scam-related consumer harm as a standing supervisory priority for 2025. #### Outlook Expect FIN-FSA to maintain fraud/scam-related consumer harm as a standing supervisory priority; absent a legislative change, Finland's non-reimbursement gap relative to the UK's APP-fraud regime persists. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://www.finanssivalvonta.fi/en/consumers/problems-with-a-service-provider/](https://www.finanssivalvonta.fi/en/consumers/problems-with-a-service-provider/) retrieved 2026-07-04 2. T3 [https://www.tuteladigitalis.com/blog/report-scam-finland](https://www.tuteladigitalis.com/blog/report-scam-finland) retrieved 2026-07-04 3. T3 [https://www.tuteladigitalis.com/blog/report-scam-finland](https://www.tuteladigitalis.com/blog/report-scam-finland) retrieved 2026-07-04 4. T1 [https://www.kkv.fi/en/consumer-affairs/consumer-ombudsman/](https://www.kkv.fi/en/consumer-affairs/consumer-ombudsman/) retrieved 2026-07-04 5. T3 [https://www.grip.globalrelay.com/fin-fsa-announces-supervisory-priorities-for-2025/](https://www.grip.globalrelay.com/fin-fsa-announces-supervisory-priorities-for-2025/) retrieved 2026-07-04 ### W11 AML/CFT & Financial Crime (Sentinel.gi-fed) [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/finland/#sec-dom-D7) Confirmed confirmed 2026-07-04 AML/CFT regime (Act 444/2017) supervised risk-based by FIN-FSA; recent focus on sanctions-monitoring gaps at PSPs and 2027-28 FATF Mutual Evaluation prep. Horizon · 2027-Q1 (±multi_year) Finland 5th FATF Mutual Evaluation_proposed · TT3_ Standing sub-brief · as of 4 July 2026 135 words · last cycle 2026-07-04 #### AML/CFT & Financial Crime This module's intelligence is sourced from the Sentinel.gi feed rather than original WPM analysis: Finland's AML/CFT framework rests on the Act on Detecting and Preventing Money Laundering and Terrorist Financing (444/2017), supervised on a risk basis by FIN-FSA, with the National Bureau of Investigation's Financial Intelligence Unit receiving suspicious-transaction reports. Also via the Sentinel feed: FIN-FSA's February 2026 sanctions risk-assessment update found that payment service providers have the most room for improvement in complying with sanctions regulations and national freezing orders, building on 2025 thematic reviews of PSPs and credit institutions - link out to the Sentinel.gi feed for the underlying illicit-finance analysis. #### Outlook Expect the Sentinel.gi feed to carry further detail on FIN-FSA's sanctions-monitoring follow-up as Finland's 2027 FATF Mutual Evaluation approaches; see the Sentinel.gi feed directly for illicit-finance analysis. no periodic updates on record for this sub-brief ** Sources and findings (10)** 1. T1 [https://www.finanssivalvonta.fi/en/financial-market-participants/banks/prevention-of-money-laundering-and-terrorist-financing/current-provisions/](https://www.finanssivalvonta.fi/en/financial-market-participants/banks/prevention-of-money-laundering-and-terrorist-financing/current-provisions/) retrieved 2026-07-04 2. T? FIM (sentinel.gi) per-JID baseline profile — Finland — Finland's AML/CFT Act implements EU 4th/5th AMLD; FIN-FSA, Police (NBI), Patent and Registry Office, regional state agencies and the Bar Association supervise obliged entities. FATF rates Finland compliant on 9, largely compliant on 28, partially compliant on 3 of 40 Recommendations (Oct 2023 re-rating), with DNFBP supervision and BO-information access still flagged as weak. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-006) — Gap: absent-field-provenance 4. T2 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-001) — Enforcement: Finnish District Court (via national prosecutors) — Transport company CEO exporting trucks/trailers to Russia 5. T2 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-004) — Enforcement: Danish Special Crime Unit (NSK), affecting Helsinki-headquartered Nordea — Nordea Bank Abp (Finland-based parent) 6. T1 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-002) — Enforcement: Finnish Border Guard/Navy as JEF ally, alongside Estonia and Sweden — Russian shadow-fleet tankers transiting the Gulf of Finland/Baltic Sea 7. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: regulatory-failure 8. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: political-constraint 9. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: enforcement-absence 10. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: capacity-deficit ### W12 Correspondent Banking, Settlement & Access Confirmed confirmed 2026-07-04 Correspondent-banking access runs primarily through Nordea (BIC NDEAFIHH); 2024 NYDFS consent order exposed material AML control gaps, prompting continued FIN-FSA follow-up. Standing sub-brief · as of 4 July 2026 152 words · last cycle 2026-08-05 #### Correspondent Banking, Settlement & Access Correspondent banking is the module's analytical spine precisely because access runs overwhelmingly through bank-owned infrastructure, leaving non-bank PIs and EMIs dependent on those same banking relationships for cross-border settlement reach. The 2024 NYDFS consent order shows exactly what that dependency can mean in practice: it detailed how Nordea's Helsinki head office processed over USD 17.7 billion in USD transactions for Latvia's ABLV Bank between 2010 and 2014 via its correspondent-banking network, with 479 of a reviewed payment sample flagged as involving high-risk parties. On the infrastructure side, Nordea's correspondent and transaction-banking operations run on TARGET2, EURO1/STEP1 and SWIFT CBPR+ settlement standards, and migrated fully to ISO 20022 (MX) messaging for all incoming and outgoing cross-border payment messages as of May 2025. #### Outlook Expect continued FIN-FSA supervisory follow-up on correspondent-banking sanctions controls at Nordea and peers, with ISO 20022 migration and CBPR+ alignment continuing as the settlement-infrastructure baseline. Periodic update · new data 2026-08-11 #### Correspondent Banking, Settlement & Access Finland's correspondent-banking and settlement-access picture this cycle is defined by a structural bank/non-bank asymmetry playing out in two directions at once. On the access side, the Eurosystem's TARGET access policy, in effect since October 2025, allows non-bank payment service providers that meet TARGET Guideline requirements to access the T2 and TIPS settlement systems directly, extending a form of settlement-system access previously reserved to banks to qualifying non-bank providers. This is a harmonised, Eurosystem-level policy rather than a Finland-specific measure, but it directly affects the settlement options available to Finnish non-bank payment institutions and e-money institutions. On the compliance side, FIN-FSA's 12 February 2026 sanctions risk assessment found that payment service providers have the most room for improvement in complying with sanctions and national freezing-order obligations, identifying non-bank payment providers specifically as the segment of greatest supervisory concern. The juxtaposition is analytically significant for this module: the same non-bank PSP segment now gaining direct access to Eurosystem settlement infrastructure is also the segment identified as carrying the weakest sanctions-compliance controls, meaning expanded settlement access and a documented compliance gap are advancing simultaneously rather than sequentially. This is a single Tier-1 source this cycle, not yet independently corroborated, which bars the finding from a Confirmed rating and holds it at High/Assessed pending a second anchor. #### Outlook Watch for whether FIN-FSA's sanctions-compliance finding produces a specific supervisory follow-up directed at non-bank payment service providers, particularly given their simultaneous gain of direct T2/TIPS access. Watch also for further Eurosystem guidance on TARGET Guideline compliance requirements for non-bank PSPs seeking direct settlement access. **Sources and findings (5)** 1. T1 [https://www.dfs.ny.gov/reports_and_publications/press_releases/pr20240827](https://www.dfs.ny.gov/reports_and_publications/press_releases/pr20240827) retrieved 2026-07-04 2. T2 [https://www.nordea.com/en/our-services/transaction-banking](https://www.nordea.com/en/our-services/transaction-banking) retrieved 2026-07-04 3. T1 [https://www.dfs.ny.gov/industry-guidance/enforcement-discipline/ea20240827-co-nordea](https://www.dfs.ny.gov/industry-guidance/enforcement-discipline/ea20240827-co-nordea) retrieved 2026-07-04 4. T2 [https://www.nordea.com/en/doc/standard-settlement-instructions-nordea.pdf](https://www.nordea.com/en/doc/standard-settlement-instructions-nordea.pdf) retrieved 2026-07-04 5. T1 [https://www.finanssivalvonta.fi/en/publications-and-press-releases/annual-reports/annual-report-2025/supervision/](https://www.finanssivalvonta.fi/en/publications-and-press-releases/annual-reports/annual-report-2025/supervision/) retrieved 2026-07-04 ### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-07-04 Trailing-12-month commercial activity centres on Paxos USDG launch, continued VC funding growth, and cross-border expansion by Coinmotion/Holvi/Nomentia. Standing sub-brief · as of 4 July 2026 151 words · last cycle 2026-08-05 #### Commercial Intelligence (M&A, Investment & Product) 2025-07-01 - Product release (completed): Paxos Issuance Europe Oy launched USDG, a MiCA-regulated USD-denominated stablecoin, across Finland and the EEA; launch scale not publicly disclosed. 2025-09-29 - Partnership (announced): Finnish treasury-tech firm Nomentia partnered with Mitigram to link treasury and trade-finance workflows for Nordic corporate clients; terms not publicly disclosed. 2025-08-22 - Market expansion: Finnish crypto trading platform Coinmotion expanded into Sweden and appointed a Sweden country manager. 2025-04-25 - Market expansion: Finnish banking platform Holvi expanded its business-banking service to Austria. Aggregate signal: Finnish FinTech companies raised USD 287 million in equity funding across 15 rounds in 2025, up from USD 175 million across 11 rounds in 2024, a 63% year-on-year increase, per Tracxn aggregate tracking. #### Outlook Expect further MiCA-licensed product launches to follow Paxos's lead and continued double-digit growth in Finnish fintech VC funding through 2026, alongside incremental cross-border expansion by domestic platforms. Periodic update · new data 2026-08-11 #### Commercial Intelligence & Fintech Finland's fintech and insurtech sector now comprises more than two hundred firms operating across payments, wealthtech, regtech, digital lending, and embedded finance. Investment conditions in the sector have become more selective, consistent with the broader European venture-capital slowdown, meaning new commercial activity is likely to be more concentrated among better-capitalised or later-stage firms than in prior growth cycles. Within the buy-now-pay-later category specifically, the Finnish market is forecast to grow 17.1 percent year-on-year to reach USD 4.74 billion in 2026, led by Klarna and Walley. Separately, the European Central Bank invited payment service providers to apply to participate in the digital euro pilot programme, with applications due by 14 May 2026; this is a cross-cutting, EEA-wide product-development opportunity directly relevant to Finnish payment service providers' roadmap planning, distinct from the BNPL market-growth figure and from the sector-scale statement, in that it represents a specific, dated commercial call to action rather than a general market observation. #### Outlook Watch for whether Finnish payment service providers participate in the digital euro pilot programme following the 14 May 2026 application deadline, and for BNPL market performance against the 17.1 percent growth forecast as the year progresses. No Finland-specific private funding-round or M&A detail was available this cycle; this is flagged as an under-indexed gap for prioritisation next cycle. **Sources and findings (5)** 1. T3 [https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/finland](https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/finland) retrieved 2026-07-04 2. T4 [https://tracxn.com/d/explore/fintech-startups-in-finland/I1YSbgynO7BiDN2aQwUujFbyfOKApiE6CRqD80jd56c#top-companies](https://tracxn.com/d/explore/fintech-startups-in-finland/I1YSbgynO7BiDN2aQwUujFbyfOKApiE6CRqD80jd56c#top-companies) retrieved 2026-07-04 3. T4 [https://tracxn.com/d/explore/fintech-startups-in-finland/I1YSbgynO7BiDN2aQwUujFbyfOKApiE6CRqD80jd56c#top-companies](https://tracxn.com/d/explore/fintech-startups-in-finland/I1YSbgynO7BiDN2aQwUujFbyfOKApiE6CRqD80jd56c#top-companies) retrieved 2026-07-04 4. T4 [https://tracxn.com/d/explore/fintech-startups-in-finland/I1YSbgynO7BiDN2aQwUujFbyfOKApiE6CRqD80jd56c#top-companies](https://tracxn.com/d/explore/fintech-startups-in-finland/I1YSbgynO7BiDN2aQwUujFbyfOKApiE6CRqD80jd56c#top-companies) retrieved 2026-07-04 5. T4 [https://tracxn.com/d/explore/fintech-startups-in-finland/I1YSbgynO7BiDN2aQwUujFbyfOKApiE6CRqD80jd56c#top-companies](https://tracxn.com/d/explore/fintech-startups-in-finland/I1YSbgynO7BiDN2aQwUujFbyfOKApiE6CRqD80jd56c#top-companies) retrieved 2026-07-04 ** No modules match.** Filters combine as OR inside a group and AND across groups. ## Editorial metadata Provenance only. Nothing below gates publication or affects the render. Editorial metadata for Finland| Field | Value | |---|---| | `trust.lawyer_review.status` | never_reviewed | | `trust.lawyer_review.reviewer` | no reviewer on record | | ` trust.content_source` | ai_generated | ## Provenance and declared absence **Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is. **Sentinel-fed modules** receive no special rendering treatment. `sentinel_feed` is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page. **Family taxonomy** is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning. **Suppressed by doctrine:** derived risk score; per-module RAG traffic light; `derived_scores` = `{"legal_accessibility": {"per_product": {"account_to_account": "regulated", "stablecoin": "emerging-regime"}}}`. **Band honesty:** uncertainty bands are computed against a frozen build clock of 2026-10-21. A year-precision row is never promoted into a tighter band. **Orphan deltas:** 1 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card. **Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 73 finding(s), 129 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).