Accountants demand SPAR citizenship data for EU AML checks

Srf konsulterna has answered the Finance Ministry's memo adapting Swedish law to the EU anti-money laundering package (Fi2026/01654)Srfkonsult with three demands on the government: authorities must carry the guidance loadSrfkonsult, supervision must not be fragmented across more county boardsSrfkonsult, and obliged entities need workable customer data plus reasonable time to adaptSrfkonsultSrfkonsult.

The package context is what makes the demands. The EU adopted its anti-money laundering package in May 2024: two regulations covering money laundering, terrorist financing, circumvention of targeted financial sanctions and the new EU authority AMLA, plus a directive on supervisory authorities and financial intelligence units. The regulations and the directive are to be completed by AMLA technical standards and guidelines that have not yet been adopted, so firms face EU rules, Swedish implementing legislation and pending detail at once.

On supervision, the memo proposes spreading the county boards' money-laundering supervision over three additional county boards on top of the three that hold the mandate todaySrfkonsult. Srf konsulterna considers that inappropriateSrfkonsult. Instead, the national coordination function against money laundering together with the supervisors should take greater responsibility for information and guidance to ansvariga enheterSrfkonsult, the obliged entities formerly called verksamhetsutövare, and the national authorities should add sector-specific guidance aimed at smaller businessesSrfkonsult. The same line runs through the sister consultation responses: supervision spread over more boards risks uneven application, while small firms without compliance functions depend on timely guidance rather than sanctions-led practice.

The sharpest operational point concerns citizenship in customer due diligence. Under the new rules, citizenship data forms part of the know-your-customer measuresSrfkonsult, and the memo's starting point is that citizenship information is publicSrfkonsult. But obliged entities cannot obtain it through the state personal address registerSrfkonsult: Skatteverket's SPAR is closed to themSrfkonsult, private actors today have no electronic route to Swedish citizenship dataSrfkonsult, and the only current source is inspection of a passportSrfkonsult, which cannot be done electronically and which not everyone in Sweden holds. That gap makes meeting the new requirements extremely challenging for an obliged entity. Srf konsulterna therefore wants section 6 of the SPAR ordinance (2026:160) amendedSrfkonsult so that obliged entities may also access birth domicile and citizenship data electronicallySrfkonsult.

The timetable point follows from the same complexity. The EU regulation starts applying on 10 July 2027FAR while AMLA standards and Swedish regulations and guidance are still being finalisedFAR, so obliged entities must be given the reasonable time they need to adapt risk assessments, routines, systems and customer processes before supervision turns to sanctionsFAR.

Legal basis: EU:s penningtvättspaket (two regulations and a directive, AMLA standards pending), promemorian Fi2026/01654 and 6 § förordningen (2026:160) om det statliga personadressregistret.