GUIDELINES FOR THE PREVENTION OF MONEY LAUNDERING AND TERRORISM FINANCING

We comply with applicable legislation to prevent our services from being used for money laundering or terrorist financing. The purpose of Trevian guidelines is to assist Trevian employees in practical and administrative issues related to the prevention of money laundering and terrorist financing. The guidelines have been supplemented with in-house operating guidelines regarding the obligation to identify and know our clients as well as risk assessments (the KYC process).  

Money laundering refers to activities in which funds of criminal or illegal origin are processed through a legal payment system in order to disguise the actual nature, origin or ownership of the funds. Terrorist financing means the acquisition or collection of funds of a legal or illegal origin for terrorist purposes. 

The Finnish Act on the Prevention of Money Laundering and Terrorist Financing (hereinafter the Anti-Money Laundering Act, 444/2017) lays down provisions on the prevention of money laundering and terrorist financing, promotes the detection and investigation of money laundering and terrorist financing and reinforces the tracing and recovery of proceeds of crime. Finnish legislation is based on the anti-money laundering directives and current recommendations of the Financial Action Task Force (FATF). 

The guidelines for the prevention of money laundering and terrorist financing and for customer identification are approved by the Board of Directors annually. 

Customer due diligence and customer identification 

As an operator in the financial sector, Trevian has a statutory obligation to identify and know its clients. The company must have up-to-date information about its clients as well as sufficient information about issues such as its clients’ activities, their financial status, use of the services, and origin of their funds. The law also obliges the company to know in which country or countries the client is generally liable to pay taxes and whether the client is a politically exposed person (PEP) or a family member of such person or a person known to be such a person’s close business partner. 

Trevian clients are bodies that purchase its real estate asset management services as well as buyers and sellers of properties. Tenants cannot be considered direct customers of Trevian, but they are clients of the landlord/our client. Trevian represents the landlord and is therefore responsible for preparing proposals for leases on which decisions are based, and it presumes that the customer due diligence and know your client processes have been carried out in compliance with the Anti-Money Laundering Act.  

Trevian uses a secure and automated DOKS® service to ensure that the customer due diligence and know your client processes are up to date throughout the contractual relationship. The service is used for customer identification, collection and maintenance of information about clients and beneficial owners in accordance with the Anti-Money Laundering Act during the customer relationship, and the client information is automatically checked against the sanction lists of Finland, the EU, the UN and the USA. The DOKS® service is used by Trevian designated KYC users. 

Obligation to obtain information and to report 

Trevian is committed to monitoring the development of its customer relationships and the use of its services as part of the organisation of business risk control. A client will be asked to provide clarification on the origin and purpose of their assets if: a) a transaction differs from the ordinary in terms of amount or structure; b) a transaction does not have an apparent financial purpose; or if c) a transaction is in conflict with the client’s financial standing or other business activities. 

Unusual or suspicious transactions are reported to the supervisor, business director or CCO, after which a report is filed to the Financial Intelligence Unit of the National Bureau of Investigation: https://ilmoitus.rahanpesu.fi/Home   

Risks related to transactions and customer relationships 

Buying and selling property is generally considered a risky industry from a money laundering perspective. Risk situations may arise in arrangements related to the sale and purchase of property and the use of property. A situation that may also present a risk can be caused by the tenant of a property who carries out activities in a property managed by Trevian that are either criminal in themselves or that are carried out with the proceeds of crimes committed elsewhere. 

Trevian clients include not only Finnish bodies but also a significant number of overseas companies. Overseas clients are generally considered to be high-risk client groups. The company’s overseas client companies are generally internationally known large global companies, which in turn reduces the risk of abuse.  

If a client is linked to entities on the EU or UN sanctions lists or to countries identified by the Commission as high-risk countries for money laundering and terrorist financing, the establishment or continuation of the customer relationship will be assessed critically and, on a case, -by-case basis.  

To minimise all risks, Trevian strictly adheres to the internal ¹KYC process guidelines and procedures in each customer relationship it establishes, although certain circumstances may indicate a lower than normal risk of abuse. The risk assessment is made when the customer relationship is established and is updated as necessary during the customer relationship. The risk assessment is prepared and maintained in the DOKS® service.  

In order to uphold a good reputation and one for trustworthiness, it is crucial to ensure that Trevian Asset Management Oy is not used to launder illegally obtained funds or otherwise enable illegal activities.  

Training on internal guidelines 

We make sure that Trevian employees already receive training as part of their induction to guarantee compliance with the Anti-Money Laundering Act and the regulations issued pursuant to it. Training is on-going and the information is continually updated. At Trevian, the Chief Compliance Officer (CCO) is responsible for compliance with the Anti-Money Laundering Act and the related regulations and internal controls.  

Approved by Trevian Asset Management Oy Board of Directors on 28 February 2024.