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, insurance companies are required to have sufficient information on the customer’s business operations, financial position, purpose for using the services, and the origin of their funds. Mandatum Life must also know the country/countries in which the customer is tax resident.
Mandatum Life is also under obligation to determine whether its customer is a politically exposed person or the family member or close business partner of such a person.
These obligations are based on legislation intended to, among other things, prevent money laundering, the funding of terrorism and financial crimes. By identifying and knowing our customers we can be a reliable partner to our customers.
We ask for your customer relationship information at the start of the customer relationship and regularly throughout it. By providing us with the information we request, you help us in our efforts to fight crime and you bear your social responsibility.
All the information you provide will be kept confidential according to the insurance secrecy obligation. Read more about how customer information is handled at Mandatum Life here.
Customer information letter – what’s it about?
- Why: We are updating obligatory customer information. To collect that information we will be sending letters during May and June.
- How: The easiest way to submit your information is by logging in to our Web Service using your Finnish banking codes at the address www.mandatumlife.fi. Alternatively, you can print up and fill in a form that can be found here » and send it to the return address stated on the form. In this case, be sure to also attach a copy of a document proving your identity, such as a passport, driving license or identification card. If you received a form with the letter please follow the instructions in the letter.
- When: We ask you to provide your information during November and December. The exact date can be found in the letter sent to you.
- Please note that you may have received the letter due to an insurance taken by your current or former employer.
- Did you receive a letter also last year? Mandatum Life has an obligation to collet information on a yearly basis.
Why are you asking for my personal information such as my place of birth or nationality?
Life 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 carrying out 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.
Why is the origin of assets significant?
Legislation seeks to ensure that funds of criminal origin cannot be modified (“laundered”) to appear as though they were acquired from legal sources, such as investment operations. Legislation on the prevention of money laundering and terrorist financing requires that we know the origin of our customers’ assets.
Why are we asking about your country of taxation?
Under international tax legislation that is binding in Finland (FATCA, CRS and DAC2), Mandatum Life must know the country/countries in which the customer is tax resident in, i.e. in which country he is subject to unlimited tax liability. A person’s unlimited tax liability is usually determined based on the person’s main place of residence or similar residence.
Why is political exposure significant?
Mandatum Life is obligated to determine whether its customer is a politically exposed person. From the legislator’s point of view, a person who holds such a position is more susceptible to being involved in, e.g., bribery. Persons holding significant positions in Finland or abroad, as well as the family members of such persons, are considered politically exposed.
The following persons are considered to be politically exposed:
- 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
- the head or board member of an international entity
- an ambassador or chargé d’affaires
A person is politically exposed if he/she holds or has held an important public function within one year. The inner circle (e.g. spouse, children, parents, business partners) of a politically exposed person is also considered politically exposed.
Why do I need to provide a copy of my driving licence or passport?
In order to guarantee secure business with us, we verify the customer’s identity in various service situations during the customer relationship. Whenever we process our customers’ information, we always ensure that it is handled appropriately and securely, without it falling into the hands of third parties.
The customer’s identity is verified using an official identity document.
We accept the following identity documents:
- 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 do business with us 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. You can log in to our Web Service using the banking codes of any Finnish bank.
What is a tax identification number, and do I have to provide it?
Each country has its own tax identification number practices, which the country’s tax authority uses to identify its taxpayers. In Finland, the personal identity code functions as the tax identification number for a private person. 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 generally liable to pay tax in another country and has been given the tax identification number for the country in question, this must be reported to Mandatum Life. Information about one’s own tax identification number is available from the tax authority of the country in question.
Where can I find more information?
If you have any questions concerning customer due diligence, please read the Q&A section below or contact Mandatum Life’s customer service at 0200 31100.
Mandatum Life cannot provide tax advice. If you do not know the country in which you are tax resident in or if you have any questions concerning taxation, please contact a tax professional or look for information on the Tax Administration’s website at www.vero.fi (use FATCA, CRS or DAC2 as search terms) or the IRS’s website at www.irs.gov.
Additional information on customer due diligence
What happens if I do not provide the information you request?
If we do not receive the information, we will address these situations on a case-by-case basis.
Is Mandatum Life the only financial sector institution requesting this information?
No. All financial institutions must comply with these legal requirements. Different financial institutions may, however, have different practices in place for acquiring information.
How do I know in which country I am tax resident in?
A person’s tax residency is usually determined based on the person’s main place of residence or similar residence.
An obligation to pay tax to the United States can arise from, among other things, US citizenship (incl. dual citizenship), a US residence permit or having a permanent address in the US.
Solely owning shares or property abroad does not generally entail an unlimited tax liability in the country in question.
I am not a customer of Mandatum Life. Why are you asking for my information?
If, for example, your current or a former employer has taken out insurance at Mandatum Life, you are, as an insurance beneficiary, Mandatum Life’s customer under the law, and Mandatum Life is under obligation to know you.
Corporate customers are identified by a document from a reliable source, such as a trade register extract. The identity of the company’s representative(s) is also verified. As proof of identification, we accept a passport, an identification card issued by the Finnish Police, and a driving licence issued after 1 October 1990.
Due to tax reporting legislation, we ask about companies’ tax unlimited liability abroad (tax residency) and their foreign tax identification number if they have one, if the country is other than Finland. In Finland, the business ID is the tax identification number for companies. If it is unclear, in which countries the company is liable to pay tax to, we advise enquiring with the Tax Administration or a tax consultant.
Ownership and beneficial owners
Mandatum Life must have sufficient information about, among other things, the company’s owners and the nature and scope of the business.
Mandatum Life must also identify the beneficial owners of its corporate customers, meaning the private persons, who own at least 25% of the company or who otherwise exercise control in the company.
We require the same information from beneficial owners as we do from private customers (except for the origin of their assets). By law, financial institutions must also determine whether their customer is a politically exposed person or the family member or close business partner of such a person. In terms of our corporate customers, this means determining whether politically exposed persons own or represent the company and are in a position where this must be taken note of in the company’s dealings.
If Mandatum Life does not obtain all or a sufficient amount of information to open a customer account or support the completion of a transaction, by law it must refuse to open a customer account or complete a transaction.
All the information and documents provided by the customer are to be kept confidential according to the insurance secrecy obligation and legislation governing personal data processing.
In addition to Finland, my company has operations in Sweden and Norway. Do I put all three countries as my tax domicile?
If a company has operations in a country other than Finland, this alone does not mean that it has unlimited tax liability in those other countries. The company is primarily liable to pay tax to Finland if it is registered in Finland or established according to Finnish legislation. If you are unsure about your company’s tax liability, we advise enquiring with the Tax Administration or a tax consultant.
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