Trevian Asset Management Oy – General Guidelines for the Prevention of Money Laundering and Terrorist Financing
Trevian Asset Management Oy complies with the applicable legislation on the prevention of money laundering and terrorist financing, as well as with the instructions issued by the authorities, to prevent the possible misuse of its services. The purpose of these general guidelines is to support personnel in practical and administrative matters related to the prevention of money laundering
and terrorist financing.
These general guidelines are supplemented by internal operating instructions concerning customer identification and verification, customer due diligence, and the preparation of risk assessments (the KYC process).
Money laundering refers to activities whereby assets originating from criminal or otherwise illegal sources are circulated through the legitimate financial system to conceal the origin, nature, or ownership of the assets.
Terrorist financing refers to the acquisition or collection of funds originating from legal or illegal sources for terrorist purposes.
The Finnish Anti-Money Laundering Act (444/2017, as amended), together with EU directives and FATF (Financial Action Task Force) recommendations, form the regulatory basis for Trevian’s operations.
These general guidelines are approved annually by the Board of Directors of Trevian Asset Management Oy.
1. Customer Due Diligence and Identification
As a financial sector operator, Trevian Asset Management Oy has a statutory obligation to:
– identify its customers and verify their identity
– collect and maintain up-to-date basic customer information
– assess the nature of the customer’s activities, financial position, purpose of the services used, and the origin of funds
– determine the customer’s countries of tax residence
– identify politically exposed persons (PEPs), their family members, and close associates.
The customers of Trevian Asset Management Oy are entities purchasing real estate asset management services, as well as buyers and sellers of real estate. Tenants are not directly Trevian’s customers, but customers of the principal. Trevian represents the landlord and prepares decisions in leasing situations, in which case customer identification and due diligence must have been carried out in accordance with the Anti-Money Laundering Act.
1.2 Use of the DOKS® Service
Trevian uses the secure and automated DOKS® service for customer identification and the maintenance of customer information. Through the service:
– identities of individuals and company details are verified
– customer and beneficial owner information is collected and updated
– sanctions list (EU, UN, UK, USA, Finland) and freezing decisions issued by the Finnish National Bureau of Investigation are monitored
– PEP lists are monitored
– KYC documentation is maintained throughout the entire customer relationship.
The service is used by Trevian’s designated KYC officers.
2. Duty of Due Diligence and Reporting
Trevian monitors the development of customer relationships and the use of services as part of its internal risk management. Additional clarification regarding the origin of funds is requested if:
– a transaction deviates from the customer’s usual activity, size, or structure
– the transaction has no clear economic or legal purpose
– the transaction does not correspond to the customer’s financial position or previous activity.
Unusual or suspicious transactions must be reported immediately to the supervisor, business director, or Chief Compliance Officer (CCO). Where necessary, a report is submitted to the Money Laundering Clearing House of the Finnish National Bureau of Investigation.
Personnel are reminded that the customer must not be informed of a report having been made (prohibition of tipping off)
3. Risks Related to Assignments and Customer Relationships
Real estate transactions are generally considered a sector with an elevated risk of money laundering.
Risks may relate to:
– the purchase and sale of real estate
– ownership or usage arrangements concerning real estate
– tenant activities, if the tenant engages in criminal activity or activity financed with proceeds of crime.
Trevian’s customer base also includes international corporate clients, which are generally considered a higher-risk customer group. Many of these companies are large and owned by wellknown parties, which reduces the risk of misuse.
If a customer has connections to sanctioned parties or high-risk countries, the initiation or continuation of the customer relationship is assessed on a case-by-case basis.
3.1 Risk Assessment
A risk assessment is carried out before establishing a customer relationship and is updated as necessary during the relationship. The assessment is prepared and stored in the DOKS® service.
Trevian complies with its internal KYC guidelines and procedures in all customer relationships, regardless of whether an individual customer appears to be at low risk.
4. Training and Internal Control
All Trevian employees are trained during onboarding to comply with the obligations of the AntiMoney Laundering Act and Trevian’s internal practices. Training is provided on a regular basis, and guidelines are updated in line with legislative changes.
Compliance with the Anti-Money Laundering Act and internal control is the responsibility of the designated Chief Compliance Officer (CCO) of Trevian Asset Management Oy.
Approved by the Board of Directors of Trevian Asset Management Oy on 23 February 2026