Measures against money laundering and terrorist financing

Storebrand should act consistently and in accordance with relevant legislation in matters relating to money laundering, terrorist financing, and economic crime in general. Storebrand should actively work to ensure that we are not used by or linked to criminal activity.

We work purposefully to protect customers and the company. Storebrand has implemented measures in its operations to prevent any of the group’s companies from being used for money laundering or terrorist financing.

This is in the form of board-approved guidelines, company-specific routines, and controls applicable to our operational processes. Each company in the group must carry out a risk assessment of money laundering, economic crime, and terrorist financing, and implement routines for customer establishment and initial and ongoing customer and transaction controls.

Emphasis is placed on professional competence, employee development, and risk understanding in relevant environments and units. In addition, a group-wide environment has been established with dedicated employees to be up-to-date on the risk picture and requirements at all times.

All employees are required to familiarize themselves with our guidelines for preventing economic crime and must complete our mandatory training program on money laundering.

The training gives employees a basic understanding of the rules that apply to money laundering, economic crime, and terrorist financing, and the requirements we place on our employees and managers. Senior executives and board members of the group and subsidiaries also receive mandatory training in money laundering, economic crime, and terrorist financing.

We conduct audits and regular spot checks to identify and report suspicious transactions or behavior.

We have developed a separate area on our intranet for work against money laundering, economic crime, and terrorist financing, where we indicate what kind of business behavior is expected from the employees. The information applies to all companies in the group.

We are an active member of Finance Norway’s committee for economic crime. The committee works closely with the authorities in Norway and provides guidance to all member companies.

As part of our work and social responsibility against money laundering and terrorist financing, we depend on knowing our customers.

Knowledge about the customers is required to be able to meet the legal requirements we are subject to and also part of our goal that we will do what we can to avoid being used for criminal activity. Based on this, our customers will be asked questions when they come to us and also along the way as customers. We must, among other things, know the purpose of the customer relationship and know how you as a customer use our products and services. We ask, for example, where money that is deposited into your products comes from, and about transfers to and from abroad.

The information you give us is treated confidentially.

All financial institutions are required to clarify whether our customers are or have a connection to a politically exposed person. The background for this is that people with such a connection globally and traditionally are more exposed to corruption, among other things. A politically exposed person is a physical person who holds, or has held in the last 12 months, a high-ranking public office or position as mentioned below.

In Norway, the following roles are defined as PEP:

• The King, Prime Minister, Minister/Minister, Deputy Minister/Assistant Minister
• Member of Parliament and alternates
• Member of the governing body of a political party, e.g., the Main Board Supreme Court
• Judge and Court of Appeal Judge
• Members and alternates of the Audit Committee in the Office of the Auditor General
• Members and alternates of the Executive Board of the Bank of Norway
• Ambassador and Chargé d’Affaires (consul is not included)
• Chief of Defense, as well as the top leaders of the various branches of defense (general, lieutenant general and major general, admiral, vice admiral and rear admiral)
• Member of the administrative, executive, or controlling body of a state-owned enterprise that performs public tasks that fall under public administration. Municipal and county municipal enterprises are not included
• Director, board member, or person in top management in an international organization (e.g., UN, EU, EFTA, NATO, and WTO)

Financial institutions must also know if our customers have a close relationship with someone who is politically exposed. Examples of this can be parents, spouse, registered partner, cohabitant, and children, as well as children’s spouses, registered partner, or cohabitant. In addition, close relationships in working life are also covered, e.g., through a close business connection or that one is the real owner of a company together with a politically exposed person. If you want to read the definitions in their entirety, you can do so on Lovdata:

Act on measures against money laundering and terrorist financing (the Money Laundering Act)

Identifying our customers is an important measure in the fight against economic crime. Stricter requirements from the authorities mean that the requirement for identification has been tightened. We must therefore ensure that you are properly identified.

We recommend that our customers identify themselves digitally with BankID.

If you do not have BankID, you must identify yourself with other identification. Then we need a copy of two documents. Other valid identification is:

• Norwegian and foreign passport (not emergency passport)
• Norwegian driver’s license (not the driver’s license app)
• Norwegian bank card with photo
• Norwegian national ID card
• National ID card issued by an EEA country
• Norwegian alien’s passport (gray passport)
• Norwegian travel document for refugees (blue passport)

The identification is valid when it has not expired at the time of presentation to us.

If you do not have two valid identification documents mentioned above, you can in addition to one valid identification document deliver:

• Copy of the latest tax return, pay slip, confirmation of payment of benefits, grants, student loans or document/letter on other public benefits

If you experience challenges with the identification, we ask you to contact us.

Trading and investing in cryptocurrency and virtual assets are legal in Norway, but due to inherent properties such as anonymity and borderless transactions, these types of products are associated with a higher risk of money laundering. Storebrand is required to follow the “know-your-customer” principle, which means that we must assess the origin of our customers’ funds. The purpose of this principle is to assure us that our customers’ funds cannot be linked to money laundering or other criminal activity.

Our guidelines

We want our customers to be familiar with our guidelines for cryptocurrency and virtual assets. Be prepared that we may contact you and ask you for an explanation and documentation related to activity related to cryptocurrency and virtual assets.

• If you want to become a customer with us, you must state in the customer declaration form that you trade cryptocurrency or intend to trade in the future.
• If your initial investment in virtual currency was made from another bank, Storebrand may ask you to document this.
• You must be able to provide a complete transaction history from the first investment to the realization of profit/loss and the basis for deposits to or withdrawals from your account in Storebrand.
• We urge all our customers to report wealth, profit, and loss to the tax authorities. For more information on how to report your values, we refer to the tax authorities’ websites.

Reservation for you who want to become a customer in the bank

Given the complex nature of cryptocurrency and virtual assets, one must expect some processing time. With missing or unsatisfactory information and documentation, you as a customer risk that the funds linked to virtual currency will be frozen on the account. In the worst case, it can end with not being granted an application for a customer relationship, or that one can be terminated as a customer.

We understand that it can be time-consuming to have to answer questions related to this, but as a bank and reporting entity, we are obliged to know our customers and conduct investigations related to the origin of the funds.