FAR backs AML package but demands workable timetable

FAR supports the purpose of the EU anti-money-laundering packageFAR and most of the Swedish implementation in memorandum Fi2026/01654FAR. The organisation welcomes that the memorandum refrains from national tightening and that Revisorsinspektionen supervision is extended to audit firms that are not registered audit companies, a change requested since 2021. At the same time the rules must be risk-based and proportionate with enough preparation timeFAR; otherwise Sweden should work for postponementFAR.

The EU anti-money-laundering regulation starts to apply on 10 July 2027FAR. For auditors, accounting and payroll consultants and tax advisers the change is extensive: risk assessments, working methods, routines, systems and training must be adapted. Several AMLA technical standards and guidelines on due diligence, monitoring and suspicious-report formats are not finally adoptedFAR, and Swedish law, regulations, guidance and technical solutions also need to be in place.

FAR argues members are gatekeepers with a full picture, not banksFAR. They do not monitor transactions in real time and normally do not manage client funds, but recurring assignments give insight into operations, ownership, accounts and payroll that can reveal deviations over time such as fictitious invoicing or unclear ownership transfers. Requirements should be judged on information reasonably available within the assignment, not on authority-only dataFAR, and should not move time from risk assessment to documentation.

Most firms are small or medium-sized or sole traders without a compliance functionFAR; about 70 percent of FAR over 5,000 members work in such firmsFAR. FAR asks for proportionate requirements reflecting size, risk and conditions, including reporting and feesFAR, plus assessment of the cumulative burden for smaller non-financial obliged entities and follow-up after application.

Supervision needs resources and competence. County-board supervision covers tens of thousands of consultants, gains new obliged categories and may spread across more boards. Riksrevisionen found in 2024 scope and effectiveness gapsFAR (RiR 2024:8). FAR opposes further spreading, asks for one coordinating board with joint guidance, resourcing statements for county boards and Revisorsinspektionen, and a study of collecting supervision of accounting and payroll consultants at the future Authority for Accounting and Auditing with state authorisation.

Transition needs time, guidance and a learning period. Law and regulations should be decided at least six months before applicationFAR, with sector-specific guidance for non-financial sectors well before 10 July 2027. First-year supervision should prioritise guidance and correction over sanctions where deficiencies stem from new or unclear requirements and the firm corrects promptlyFAR. Otherwise the national date should be postponedFAR and Sweden should seek EU timetable adjustmentFAR. Firms should not face intervention for late rules.

On the sections FAR supports not using the Article 6, 29.6 and 34.6 options, collecting citizenship data at ordinary updates with customer statements sufficient at normal risk, Bolagsverket notification with low cost-based fees and one registration per legal person, and keeping the current authority structure. It asks to clarify that external revisorer means external accountants doing bookkeeping, to set a 30-day change-notification limit, and to keep Revisorsinspektionen as sole AML supervisor for the legal person.

FAR opposes going beyond the directive on suitability with vague business-neglect or serious-crime tests, annual statutory sampling, sanction fees combined with reminder outside Article 55.1 second-paragraph cases, and strict liability for natural persons without intent or gross negligence. Formal minor deficiencies should meet guidance and correction first, with firm and personal liability separated and one joint decision where conduct breaches both AML and auditing standards.

Legal basis: Europaparlamentets och rådets förordning (EU) 2024/1624 on preventing use of the financial system for money laundering or terrorist financing, the Sixth Anti-Money-Laundering Directive on supervision and cooperation, and promemorian EU:s penningtvättspaket Fi2026/01654 with FAR remissvar 29 October 2026.