Three lines of defence

Prevention of financial crime requires an effective organisational structure and operating model. At Nordea, we have established three lines of defence, and each of these has a defined role in our financial crime risk management and internal controls.

Daily risk management, operations and development

Our customer-facing employees and expert units form the first line of defence. They are responsible for daily risk management and for carrying out everyday work based on Nordea's policies, instructions and guidelines in relation to managing the risk of financial crime. This includes ensuring we know our customers, monitoring activity for unexpected behaviour and reporting suspicious activity to relevant authorities. 

In addition, the first line of defence develops and maintains the tools required to carry out effective financial crime risk management.

Monitoring and reporting

The second line of defence consists of our compliance and risk functions. These functions ensure we conduct business in accordance with applicable laws, rules and standards by overseeing and monitoring the daily operations and providing advice to the first line of defence. The second line of defence plays a key role in anchoring the principles of integrity and fair dealing in our business and having effective risk management processes in place.

Internal audit

The third line of defence is our Internal Audit function. Internal Audit performs independent assurance activities to evaluate and improve the effectiveness of governance, risk management and control processes, to support the board and senior management in protecting Nordea’s assets, reputation and sustainability.

A battle we cannot fight alone

Financial crime is a broader societal issue which no financial institution can battle alone. 

We work together with a wide range of external stakeholders, including financial supervisory authorities, industry associations, tax authorities and the financial intelligence units in each of the countries we operate in. As required by law, we report suspicious activities, behaviour and transactions to local financial intelligence units.

Learn more about sanctions

Training in financial crime prevention

At Nordea, we consider financial crime prevention to be a shared responsibility that involves all employees. We ensure all our employees have the right skill set and competences by continuously providing relevant training.

  • All employees are required to complete our ‘License to Work’ which is a risk and compliance, training program that gives employees the necessary information and knowledge to mitigate risks, act with high ethical standards and conduct business in a responsible way.  
  • All employees take mandatory training on financial crime prevention and, advanced courses and certifications are offered individually to our financial crime specialists as well. 
  • Our internal training include realistic and specific situations to make the information relevant and practical, and the courses are regularly updated to reflect new developments in financial crime trends and regulation