Knowing and identifying the customer – why are we asking?

As a financial institution, Mandatum has a legal obligation to identify and know its customers. In addition to up-to-date personal information, the company is required to have sufficient information on, among other things, its customers’ business operations, financial position, purpose for using the services, and the origin of their funds. Mandatum must also know the country/countries in which the customer is generally liable to pay tax.

Mandatum is also under obligation to determine whether its customer is a politically exposed person or the family member or close business partner of such a person.

These obligations are based on legislation intended to, among other things, prevent money laundering, the funding of terrorism and financial crimes.

We ask for your customer relationship information at the start of the customer relationship and regularly throughout it. By providing us with the information we request, you help us in our efforts to fight crime and you bear your social responsibility.

All the information you provide will be kept confidential according to the insurance secrecy obligation. Read more about how customer information is handled at Mandatum here.

Customer data letter – what does it mean?

• Why: We are updating our statutory customer data, which is why we send out letters in May and June requesting information.
• How: The simplest way is to update your information in our Web Service, where you can log in using your personal banking codes. A questionnaire will open up automatically after you log in. If you prefer, you can also print up the form on this page » and send it to the address mentioned in the form. In this case, be sure to also attach a copy of a valid document proving your identity, such as a passport, driving licence or identification card. If you receive the form along with the letter, please fill in the form as instructed in the letter.
• When: We kindly ask you to supply the requested information in June.
• Please note that you might receive a letter requesting customer information, for example, for insurance taken out by your current or former employer.
• Did you also receive a letter last year? Mandatum Life is obligated to request any missing information every year.

‘Private customer’s basic information’ form

Why am I being asked for my personal information, such as my place of birth or nationality?

Mandatum is always obligated to know its customers. We ask many kinds of questions in order to be able to serve you better, but by practicing customer due diligence, we are also fulfilling our legal obligations. We are obligated to ask, for example, the customer’s name, place of birth, national identity number, address and other contact details.

Why is the origin of assets significant?

Legislation seeks to ensure that funds of criminal origin cannot be modified (“laundered”) to appear as though they were acquired from legal sources, such as investment operations. Legislation on the prevention of money laundering and terrorist financing requires that we know the origin of our customers’ assets.

Why am I being asked about my country of taxation?

Under international tax legislation that is binding in Finland (FATCA, CRS and DAC2), Mandatum must know the country/countries in which the customer is generally liable to pay tax, i.e. the customer’s tax domicile. A person’s general tax liability is usually determined according to the person’s main place of residence or similar residence. International tax legislation requires determining tax liability.

Why is political exposure significant?

Mandatum is obligated to determine whether its customer is a politically exposed person. A person who holds such a position is, from the point of view of a legislator, more susceptible to being involved in, e.g., bribery. Persons holding significant positions in Finland or abroad, as well as the family members of such persons, are considered politically exposed.

The following persons are considered to be politically exposed:

1. A head of state, minister, member of parliament or member of a governing body of a political party
2. A member of the highest court, constitutional court, court of auditors, other similar legal body or the highest decision-making body in charge of controlling public finances
3. An officer who is at least a general in the military
4. A member of the administrative, executive or supervisory body of a company that is wholly owned by the state or member of the executive board of a central bank
5. The head or board member of an international entity

an ambassador or chargé d’affaires

A person is politically exposed if he/she holds or has held an important public function within one year. The inner circle (e.g. spouse, children, parents, business partners) of a politically exposed person is also considered politically exposed.

Why do I need to provide a copy of my driving licence or passport?

We verify the customer’s identity in various service situations during the customer relationship in order to guarantee secure business. Whenever we process our customers’ information, we always ensure that it is handled appropriately and securely, without it falling into the hands of third parties.

The customer’s identity is verified using an official identity document. We accept the following identity documents:

• Passport
• Identification card granted by the Finnish Police
• Driving licence granted after 1 October 1990

The identification card must be intact and in force.

You can also take care of matters securely by logging in to our Web Service using your Finnish banking codes. The Web Service enables you to send messages to us on the Messages page or update your details on the ‘My account’ page. If your information needs to be updated, a short customer information form will open up when you log in. You can continue onto our Web Service once you fill in the form. You can log in to our Web Service using the banking codes of any Finnish bank.

What is a tax identification number and do I have to provide it?

Each country has its own tax identification number practices, which the country’s tax authority uses to identify its taxpayers. In Finland, the personal identity code functions as the tax identification number for a private person. Most countries have a separate tax identification number, but some countries may use a combination of several numbers to identify its taxpayers (e.g. France). If a customer is generally liable to pay tax in another country and has been given the tax identification number for the country in question, this must be reported to Mandatum. Information about one’s own tax identification number is available from the tax authority of the country in question.

Where can I find more information?

If you have any questions concerning customer due diligence, please read the Q&A section below or contact Mandatum's customer service at 0200 31100.

Mandatum cannot provide tax advice. If you do not know the country in which you are generally liable to pay tax or if you have any questions concerning taxation, please contact a tax professional or look for information on the Tax Administration’s website at www.vero.fi (use FATCA, CRS or DAC2 as search terms) or the IRS’s website at www.irs.gov.

Additional information on customer due diligence: Financial Supervisory Authority

Due diligence on a company or entity

Identification

Corporate customers are identified by a document from a reliable source, such as a trade register extract. The identity of the company’s representative(s) is also authenticated. As proof of identification, we accept a passport, an identification card issued by the Finnish Police, and a driving licence issued after 1 October 1990.

Tax liability

Due to tax reporting legislation, we ask about companies’ tax liability abroad (tax domicile) and their foreign tax identification number if they have one, if the country is other than Finland. In Finland, the business ID is the tax identification number for companies. If it is unclear which countries the company is liable to pay tax to, we advise enquiring with the Tax Administration or a tax consultant.

Ownership and beneficial owners

Mandatum must have sufficient information about, among other things, the company’s owners and the nature and scope of the business.

Mandatum must also identify the beneficial owners of its corporate customers, meaning the private persons who own at least 25% of the company or who otherwise exercise control in the company.

We require the same information from beneficial owners as we do from private customers (except for the origin of their assets). By law, financial institutions must also determine whether their customer is a politically exposed person or the family member or close business partner of such a person. In terms of our corporate customers, this means determining whether politically exposed persons own or represent the company and are in a position where this must be taken note of in the company’s dealings.
If Mandatum does not obtain all or a sufficient amount of information to open a customer account or support the completion of a transaction, by law it must refuse to open a customer account or complete a transaction.

All the information and documents provided by the customer are to be kept confidential according to the insurance secrecy obligation and legislation governing personal data processing.

Where can I find more information?

If you have any questions concerning FATCA, please read the Q&A section below or contact Mandatum’s customer service at 0200 31100.

Mandatum cannot provide tax advice relating to FATCA and CRS. If you have any questions concerning taxation, please contact a tax professional or look for information on the Tax Administration’s website at www.vero.fi (use FATCA or CRS as the search term) or on the IRS’s website at www.irs.gov.

Additional information on customer due diligence
Financial Supervisory Authority
Finance Finland