Knowing our customers makes us a reliable partner

We have a legal obligation to identify our customers. We handle the information we receive with strict confidentiality.

Knowing and identifying the customer – why are we asking?

As a financial institution Mandatum Life has a legal obligation to identify and know its customers. In addition to up-to-date personal information we need to know the customer’s financial position and the origin of their assets. Insurance companies must also have sufficient information on their customers’ operations, financially and politically influential positions, what services they use and for what purpose. In addition, Mandatum Life needs to know to which country the customer is paying taxes.

These obligations are based on legislation intended to, among other things, prevent money laundering, the terrorism financing and financial crimes. By identifying and knowing our customers, we can be a reliable partner to our customers.

We ask our customers for information at the beginning of the customer relationship and regularly throughout it. All of the information provided will be kept confidential according to the insurance secret. Read more about how customer information is handled at Mandatum Life here.

Why are you asking for my personal information such as my place of birth or nationality?

Insurance companies are always obligated to know their customers. We ask many kinds of questions in order to be able to serve you better, but by practicing customer due diligence, we are also fulfilling our legal obligations. We are obligated to ask, for example, the customer’s name, place of birth, national identity number, address and other contact details.

What significance does political influence have?

Mandatum Life is also under obligation to determine whether its customer is a politically exposed person. Finland’s anti-money laundering legislation will be amended in June 2017. Following the amendment, persons in significant positions in Finland will also be considered politically exposed. A person is considered a politically exposed person if he/she is:

  • a head of state, minister, member of parliament or member of a governing body of a political party
  • a member of the highest court, constitutional court, court of auditors, other similar legal body or the highest decision-making body in charge of controlling public finances
  • an officer who is at least a general in the military
  • a member of the administrative, executive or supervisory body of a company that is wholly owned by the state or member of the executive board of a central bank
  • head or board member of an international entity
  • an ambassador or chargé d’affaires

The person is politically exposed if he/she holds or has held a significant public position within one year. Such a person’s inner circle (e.g. spouse, children, parents, business partners) are also considered politically exposed. This does not, however, mean that we ask for our customers’ political opinions.

Why do I need to provide a copy of my driving licence or passport?

We confirm the customer’s identity more and more often during the customer relationship in various service situations. This allows us to ensure that the information provided by the customer is handled appropriately and securely, without it falling into the hands of third parties.
The customer’s identity is confirmed using an official identity document.

The customer’s identity is confirmed through an official identity card. We accept the following identity documents:

  • Passport
  • Identification card granted by the Finnish Police
  • Driving licence granted after 1 October 1990

The identification card must be intact and in force.

You can also take care of matters securely by logging in to our Web Service using your Finnish banking codes at the address www.mandatumlife.fi. The Web Service enables you to send messages to us on the “Messages” page or update your details on the “My account” page. If your information needs to be updated, a short customer information form will open up when you log in. You can continue onto our Web Service once you fill in the form.

I received a letter concerning customer information and taxation (FATCA and CRS), what do I need to do?

If you received a letter from Mandatum Life or Kaleva concerning customer information and your country of taxation, please fill in the attached form (or alternatively one of the forms below) and return it to us. You can also provide the information by logging in to our Web Service with your banking codes and filling in the customer information form that opens up.

If we do not receive the requested information or if we cannot rule out your tax obligation abroad based on other information, we are obligated to report on this to the Finnish Tax Administration.

Client

IRS form

IRS’s instructions

Persons who are not US taxpayers

Form W-8BEN or customer basic information

Instructions W-Ben

Organisations which are not US taxpayers

Form W-8BEN-E or institutional customer’s basic information

Instructions W-8BEN-E

Persons and Institutions that are taxpayers in the US

Form W-9

Instructions W-9

Why do I need to give my country of taxation (FATCA and CRS)?

It is Mandatum Life’s obligation to determine the customer’s tax domicile. This obligation is based on the Foreign Account Tax Compliance Act (FATCA) and the OECD’s Common Reporting Standard (CRS). The objective of FATCA is to prevent the tax evasion of persons who are liable to pay tax in the United States. The objective of CRS is to implement the automatic exchange of tax information worldwide.

FATCA – tax obligation in the United States

Finland and the United States have agreed on an exchange of information related to United States FATCA legislation. According to the agreement, financial institutions such as banks, mutual fund companies, investment service companies and life insurance companies must identify their US customers and report on their US customers’ investments to the United States’ Internal Revenue Service (IRS). The reporting takes place through the Finnish Tax Administration. FATCA was included in Finland’s legislation in 2015.

US persons mean, among other things, persons living in the US, US citizens (also those with dual citizenship), persons with a permanent residence permit and companies registered in the United States. In addition a US person may be a company that is owned by a US person.

Common Reporting Standard (CRS) and DAC II

The Common Reporting Standard (CRS) is an exchange of information model developed by the OECD, stemming from the need to create an international exchange of information standard based on FATCA, and related instructions. In October 2014, Finland signed an agreement concerning the exchange of information according to CRS, together with 50 other states. Altogether some 100 countries are committed to initiating CRS information exchange.

DAC II is a European Union directive through which the exchange of information according to CRS is implemented between EU member states.

Where can I find more information?

If you have any questions concerning FATCA, read the Q&A or contact Mandatum Life’s customer services p. 0200 31100.

Mandatum Life cannot provide tax advice relating to FATCA and CRS. If you have any questions concerning taxation, please contact a tax advisor or look for information on the Tax Administration’s website at www.vero.fi (use FATCA or CRS as the search term) or on the IRS’s website at www.irs.gov.

Additional information on customer due diligence

What is FATCA?

FATCA (Foreign Account Tax Compliance Act) is part of US legislation. Its purpose is to prevent tax evasion by US persons through international investments and deposits. FATCA applies to all financial institutions around the world. Finland signed an agreement concerning the exchange of tax information with the United States in 2014 (FATCA agreement). The agreement was included in Finland’s legislation in spring 2015.

Who are considered to be US persons?

US persons are considered to include: US citizens (also those with dual citizenship, persons with a permanent residence permit or who permanently reside in the United States, companies registered in the United States and certain companies whose owner is a US person.

What impact does FATCA have?

According to FATCA, financial institutions such as banks, mutual fund companies, investment service companies and life insurance companies must identify their US customers and report on their US customers’ investments and deposits to the United States’ Internal Revenue Service (IRS). The reporting takes place through the Finnish Tax Administration. Due to the FATCA agreement, Mandatum Life is required to determine the possible tax obligations of current and new clients in the United States. Mandatum Life will contact its clients for more information, if necessary. In order to fulfil the statutory demands set by FATCA, Mandatum Life will ask its customers for, among other things, their place of birth and their foreign taxpayer identification number.

Is Mandatum Life the only financial sector institution that does this?

No. All financial institutions need to comply FATCA’s requirements. Different financial institutions may, however, have practices that differ from Mandatum Life’s, such as in determining the tax obligations of current clients.

Another financial institution contacted me. Why is it asking for different documents than Mandatum Life?

Financial institutions may have different practices in collecting information from their customers in order to determine their FATCA status and they may use different forms than Mandatum Life. Mandatum Life cannot provide tax advice relating to FATCA. If you have any questions concerning taxation, please contact a tax advisor or look for information on the Tax Administration’s website at www.vero.fi (use FATCA as the search term) or from the IRS’s website at www.irs.gov.

What does Mandatum Life need to do to fulfil its obligations concerning FATCA?

Mandatum Life has the following obligations, among others: Mandatum Life must review its current and new customers and identify those customers who have tax obligations in the United States. Mandatum Life must annually report the savings and investments of its US customers to the Finnish Tax Administration, which then reports the information to the Internal Revenue Service (IRS). Mandatum Life must also report information to the Tax Administration on contracts whose owners do not respond to the FATCA-related questions.

Does FATCA take the place of other US tax laws?

No. FATCA only applies to the process and reporting related to the requirement that financial institutions must know their customers. It does not impact tax laws that you must otherwise take into account. Mandatum Life recommends that you turn to a tax advisor in any tax law related issues.

What information does Mandatum Life report to tax authorities?

The reported information includes the name, address, tax identification number of the US person and the numbers and balances of contracts.

What impact does FATCA have on individual persons?

Legislation specifies several criteria that financial institutions must pay attention to when attempting to identify US persons among their customers. If the customer fulfils any of these criteria he/she may be contacted for additional information: United States citizenship (also dual citizenship), residence in the US, born in the US, work permit (Green Card), person spends a significant portion of their time in the United States each year, US address in Mandatum Life’s customer register, US telephone number in the customer register, repeat payments (e.g. pension) to an account in the US, power of attorney or procuration rights given to person with US address, c/o address is the only address in the customer register. Please note that Mandatum Life reviews its customer base in its entirety in order to identify US persons. This is why Mandatum Life may also contact people who are not US persons.

I am not a US person. How does this affect me?

If you are not a US person this matter does not affect you. Mandatum Life may, however, contact you in order to confirm your status as a non-US person.

What impact does FATCA have on companies and institutions?

FATCA’s impacts extend to US companies and companies from other countries whose beneficial owner (owner/user of controlling interest) is a US person.

What documents do I need to submit?

If necessary, Mandatum Life will contact its clients for more information and explain what information it requires and what forms need to be filled in. The forms may be Mandatum Life’s own forms or the IRS’s forms (W-forms).

Will Mandatum Life supply all of the necessary forms?

Yes. When we contact a customer we will send the required forms as an attachment or links to downloadable forms on our website.

What will Mandatum Life do if I do not supply the information required by FATCA?

According to FATCA, customers that do not supply the information required for confirming their FATCA status are to be considered US persons in reporting. In this case, Mandatum Life will report the customer’s information to the Finnish Tax Administration.

Why do Mandatum Life’s forms contain non-FATCA-related questions, for example the origin of the assets?

Mandatum Life is obligated to identify and know all of its customers based on legislation on, for example, the prevention of money laundering. In addition, we are obligated to identify all of those customers whose tax domicile is a country other than Finland. The obligations stem from FATCA and corresponding projects in the OECD countries and the EU, the purpose of which is to prevent tax evasion to other countries by corporate and private taxpayers through foreign financial institutions.

What is the tax identification number and do I have to provide it?

Each country has its own tax identification number practices with which the country identifies its taxpayers. In Finland the personal identity code functions as the tax identification number for private persons. The business ID is the tax identification number for companies. Most countries have a separate tax identification number but some countries may use a combination of several numbers to identify its taxpayers (e.g. France). If a customer is liable to pay tax in another country and he/she has been given the tax identification number for the country in question, this must be reported to Mandatum Life.

I own a flat in the United States, am I thus liable to pay tax in the US?

In principle simply owning a flat does not make you a US taxpayer unless the United States is your tax domicile otherwise as well.

Which form should I submit, Mandatum Life’s form or a W-form?

If you are liable to pay tax in the United States (US person) you must submit form W-9. If you are not liable to pay tax in the United States you can submit either Mandatum Life’s form or form W-8.

Send a message

A simple and safe way for customers to contact us is to send us a message through our Web Service

Call

Our Customer Service number

0200 31100
(lnc/mpc) Mon to Thu 8-17 and Fri 8-16

Call

Our Customer Service number for Corporate Customers

0200 31190
(lnc/mpc) Mon-Fri 8-17

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