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We promoted several measures to combat misconduct 

Combating of misconduct comes under the UN Sustainable Development Goal of peace, justice and strong institutions (16).

No misconduct or offences concerning financial management were identified at the PRH during 2023 and there were no irregularities related to EU funding or transactions involving recovery.

Under our financial rules, each PRH staff member must report any misconduct that they have observed. The prime responsibility for combating misconduct rests with the PRH management.

Whistleblowing channel

Developing a reliable internal whistleblowing channel was one of the four measures to combat misconduct identified in 2022 that we started to promote at the PRH.

We opened the internal whistleblowing channel required under the Whistleblowing Act in March 2023. We made the whistleblowing channel more extensively available than what is set out in the Whistleblowing Act, which means that in addition to the matters falling within the scope of the Act, other types of suspected misconduct can also be reported.

Moreover, at the PRH, whistleblowers can give their contact details or report their suspicions anonymously.

The purpose is to lower the threshold for reporting suspected misconduct. Even if the misconduct did not meet the criteria for the serious act referred to in the Whistleblowing Act, the misconduct may nevertheless violate the PRH’s ethical guidelines and must therefore be addressed.

In 2023, we processed one report outside the scope of the Whistleblowing Act. On the basis of the information received, it was found out that no misconduct had taken place but the report nevertheless warranted a more detailed examination of the PRH’s internal guidelines.

In 2023, the PRH did not receive reports for processing as a competent authority through the external whistleblowing channel of the Office of the Chancellor of Justice.

The whistleblowing channel plays an important role in ensuring the legality of the PRH’s activities. After the first year of operations, we will examine our staff’s experiences of the whistleblowing channel so that we can develop it into a more effective reporting instrument.

We started the work to introduce an anti-corruption model

The other measures to combat misconduct identified in 2022 concerned corruption and increasing awareness of corruption and the introduction of an anti-corruption action and reporting model.

Our message to our staff members was that observations or suspicions concerning corruption and bribery should be reported to the internal whistleblowing channel.

During 2023, we arranged our first workshop to discuss corruption and how corruption could occur at the PRH. We will use the results of the workshop in the preparation and implementation of an operating model based on the central government anti-corruption guidelines during 2024.

More effective enforcement of sanctions

During 2023, we took a number of measures to make the national enforcement of sanctions more effective. We carried out audits of incoming matters and PRH-maintained registers and reported our findings to the competent authorities.

We established a working group on sanctions to ensure close cooperation and to share information. We prepared a policy to enforce sanctions at the PRH. Work to increase awareness of sanctions at the PRH will continue.

We continued to develop the register of beneficial owners

The activities of companies involve a higher risk of money laundering and terrorist financing because the persons behind companies’ operations do not always act in their own name.

To reduce the risk, companies are obliged to report the details of their beneficial owners to the Trade Register and to keep the information up to date. The PRH started registering details of beneficial owners in July 2019.

In 2023, we continued the development of a comprehensive, up-to-date and quality-confirmed register of beneficial owners and an information service for matters concerning beneficial owners. In addition to ensuring the timeliness and comprehensiveness of the register, we are also working to digitalise official processes and increase automated data processing.

Corresponding parties in other Member States should also have access to information on beneficial owners through BORIS (Beneficial Ownership Registers’ Interconnection System of the EU). In 2023, we continued to develop our systems to establish a functional link between the national register and the EU-maintained consortium of the registers of beneficial owners.

Developing the register of beneficial owners is part of the European Union’s digitalisation project, which is funded from the Recovery and Resilience Facility (RRF).

The PRH received more notifications of beneficial owners

In 2023, we updated the online start-up notifications for limited liability companies. Under the updated system, new companies can report the details of their beneficial owners as part of the start-up process and do not need to wait until after the registration.

The aim of the reform was to encourage more limited liability companies to report the details of their beneficial owners. In fact, significantly more notifications of beneficial owners were submitted during 2023 than in the years before that.

In 2023, we also sent letters to more than 44,000 limited liability companies and co-operatives reminding them of their obligation to report details of beneficial owners. We also prepared a liquidation and deregistration procedure, as a result of which a failure to submit a notification of beneficial owners may lead to the removal of a limited liability company and a co-operative from the Trade Register. The procedure will be introduced in 2024.

The notification of beneficial owners as part of the establishment of a limited liability company has been implemented with EU funding.

We supervised the work of auditors and provided them with advice

Auditors play a key role in the identification of suspicious business activities and thus also in the combating of money laundering and terrorist financing.

The Anti-Money Laundering Act imposes obligations on auditors, and compliance with these obligations is supervised by the PRH.

As a result of the partial reform of the Anti-Money Laundering Act, we updated the guidelines for auditors and also promoted investigation matters related to compliance with the sanctions legislation launched in 2022. No new anti-money laundering audits were launched in 2023.

The task of the PRH is also to provide auditors with advice. In 2023, we arranged two information and discussion events for auditors on the Anti-Money Laundering Act.

The PRH was also represented in the national cooperation team of public officials to combat money laundering and terrorist financing.