Fintech Regulatory Compliance In Finland.

Regulatory Framework for Fintech in Finland

Primary Regulatory Landscape

Fintech companies in Finland must comply with a complex regime of EU and national laws, enforced mainly by the Finnish Financial Supervisory Authority (FIN‑FSA or “Fiva”) and other competent authorities:

Markets in Crypto‑Assets Regulation (MiCA) — EU‑wide regime directly applicable, governing crypto‑asset services and service providers. Finland integrated this into national supervision, replacing prior local crypto laws.

Act on the Provision of Crowdfunding Services (APCS) — national law aligned with EU rules for crowdfunding service providers.

PSD2 / Payment Services Regulation — governs payment institutions and fintechs providing payment initiation or account information services.

Anti‑Money Laundering & Counter‑Terrorist Financing (AML/CTF) regulations — Finnish AML/CTF Act (444/2017) with FIN‑FSA supervising compliance; technical AML guidelines updated for crypto providers.

General Data Protection Regulation (GDPR) — rigorous EU privacy law applied in Finland, enforced by the Office of the Data Protection Ombudsman.

Consumer Protection and Competition Law Rules — applicable to fintech products marketed to the public.

Key point: Finnish fintech regulatory compliance is not only about financial licensing — firms must also align with AML, data protection, corporate conduct, and consumer protection regimes.

📌 2. Role of FIN‑FSA in Fintech Compliance

The Finnish Financial Supervisory Authority (FIN‑FSA) enforces financial and fintech compliance by:

Licensing fintech entities (payment institutions, e‑money institutions, investment firms, CASPs under MiCA).

Monitoring AML/CTF compliance, risk management and internal controls.

Conducting on‑site and off‑site inspections; issuing warnings, administrative sanctions, and penalty payments.

Revoking authorisations or limiting operations for serious regulatory breaches.

FIN‑FSA cooperation with other authorities (e.g., Data Protection Ombudsman) ensures fintechs comply across multiple regulatory dimensions.

📌 3. Core Compliance Areas for Fintechs

Compliance DomainRequirements
Licensing/RegistrationSecure authorisation under financial services law or MiCA (for crypto services) before operations begin.
AML & KYCEstablish risk assessment, customer due diligence, transaction monitoring, suspicious activity reporting.
Data ProtectionGDPR compliance, breach protections and user consent mechanisms.
Consumer ProtectionClear disclosures, suitability assessments, fair marketing.
Cybersecurity & Operational ResilienceAdequate infrastructure, incident response and security controls (implicit under MiCA and GDPR).
Corporate GovernanceCompetence and oversight mechanisms for management and board.

📌 4. Case Law and Enforcement Examples

Below are six enforcement or judicial decisions illustrating how regulatory compliance is operationalised or contested in Finland’s fintech and related financial sectors.

Case 1 — FIN‑FSA Administrative Sanction for AML Failures (2024–2025)

Issue: Two Finnish money remittance companies failed to meet AML risk assessment and customer due diligence requirements.
Outcome: FIN‑FSA imposed fines (e.g., ~€25,000 and a larger ~€500,000 penalty for LocalBitcoins Oy AML breaches).
Principle: Strict AML compliance is mandatory; failure triggers regulatory sanctions.
Significance: Highlights application of the AML Act in fintech‑relevant services (remittances/crypto).

Case 2 — Finnish Bank Data Protection Fine (2025 Administrative Decision)

Issue: A Finnish bank was found to violate GDPR security and data handling requirements via operational risk failures.
Outcome: The national supervisory authority imposed an €1.8 million fine for GDPR breaches and related operational risk neglect.
Principle: GDPR enforcement applies strongly to financial institutions, with high penalties for inadequate protections.
Significance: While a bank case, similar GDPR risk profiles apply to fintechs handling personal financial data.

Case 3 — GDPR Enforcement and Corporate Liability (Vastaamo)

Issue: Massive breach of sensitive psychotherapy client data under GDPR obligations.
Outcome: Provider fined ~€608,000 for failure to protect personal data; executives criminally convicted for data protection violations.
Principle: GDPR liability can include administrative fines and criminal sanctions for negligence in data security.
Significance: Demonstrates consequences when digital systems lack compliance‑driven design — a caution for fintech platforms.

Case 4 — Supreme Administrative Court Interpretation of GDPR Transparency Requirements

Issue: Post Office (Posti Group Oyj) initially had GDPR fine annulled; later the Supreme Administrative Court upheld a fine for transparency violations.
Outcome: Court confirmed the strict application of transparency obligations under GDPR.
Principle: Regulatory compliance cannot be bypassed by procedural errors; transparency is foundational.
Significance: Impacts fintech obligations to communicate how user data is processed.

Case 5 — FIN‑FSA Penalties for Investment Suitability Failures (Inspection Outcomes)

Issue: Multiple financial firms failed to obtain adequate customer information and assess suitability of investment advice.
Outcome: FIN‑FSA imposed fines and warnings; firms retain right of appeal.
Principle: Suitability and documentation requirements are core to investor protection compliance.
Significance: Though not pure fintech, it underscores compliance duties relevant to fintech advisory and trading platforms.

Case 6 — Crypto Service Providers Cease Operations Without MiCA Licence (Regulatory Action)

Issue: With MiCA’s full application and no licences issued, crypto service providers lost ability to operate legally in Finland.
Outcome: FIN‑FSA terminated registration of virtual asset service providers due to failure to secure MiCA authorisation.
Principle: Operating without proper authorisation results in regulatory closure.
Significance: Enforces strict licensing compliance under EU and national crypto‑asset frameworks.

📌 5. Summary: Legal and Regulatory Compliance Risks in Finnish Fintech

Compliance Risk AreaPotential Legal Consequences
Operating Without LicenceTermination of services; enforcement actions.
AML/KYC FailuresFines, sanctions and orders to remediate.
GDPR ViolationsHigh administrative fines; criminal liability in severe cases.
Inadequate Customer SuitabilityRegulatory penalties for investor protection failures.
Misleading Consumer CommunicationsConsumer authority actions under competition/marketing laws.

📌 6. Key Compliance Takeaways for Fintech Operators in Finland

Secure the Right Authorisations First: Payment, crypto, and investment technologies must be licensed under respective EU and national regimes.

AML/KYC Must Be Operationalised: Documentation, risk assessments, reporting, and FIU cooperation are mandatory.

Data Protection Cannot Be an Afterthought: GDPR and Finnish data protection laws impose substantial liabilities.

Governance and Internal Controls Matter: Regulators assess not only outcomes but processes.

Multi‑Agency Compliance: Beyond FIN‑FSA, operators must consider competition law and consumer protections as part of compliance.

LEAVE A COMMENT