Legislation
Legislation
Finnvera's and its subsidiary's operations are governed by and organised according to the Limited Liability Companies Act and the Acts pertaining specifically to Finnvera as well as by the industrial and ownership policy goals determined by the State.
In addition to the legislation and the company’s own Articles of Association, Finnvera complies with the recommendations of the Financial Supervisory Authority and the Finnish Corporate Governance Code, whenever applicable. Bank regulation defined in the EU's credit institutions directive is not applied to Finnvera's operations.
Since the decisions made by Finnvera on financing are bound by the legislation, the same predetermined criteria are used to assess each financing decision. These criteria are based on the assessment of the various components of profitability in the enterprise’s business. Acting within this framework, Finnvera applies independent discretion when carrying out its tasks.
Are you unhappy with our decision?
Finnvera’s financing decisions, or the assessment of the credit risk and the profitability of the applicant’s business, are not subject to the right of appeal. However, the client always has the option of applying for financing again.
Furthermore, anyone who suspects that a body discharging public administrative duties, such as Finnvera, has acted unlawfully or has not fulfilled its duties is entitled to lodge an administrative complaint in accordance with Chapter 8a of the Administrative Procedure Act. The complaint is submitted in writing to the Ministry of Economic Affairs and Employment, which supervises Finnvera’s activities. In its decision, the Ministry of Economic Affairs and Employment may draw Finnvera's attention to the requirements of good governance or may inform of the Ministry’s understanding of the lawful procedure.
Any suspicions of malpractice or breach of operating principles can also be confidentially brought to the knowledge of Finnvera’s Risk Management via whistleblowing channel.
State aid rules
As a publicly owned financing company, Finnvera must comply with EU state aid regulations when providing financing services.
Finnvera does not grant direct support or grants to companies, but Finnvera’s financing includes so-called imputed state aid. If the price or terms of Finnvera’s financing are below the EU’s market price level, the price difference is considered imputed aid.
- The imputed aid included in Finnvera’s financing is primarily provided as so-called de minimis aid. A company may receive a maximum of EUR 300,000 in de minimis aid from different state or municipal actors over a three-year period. For the fisheries sector, the maximum amount of de minimis aid is EUR 30,000 over a three-year period.
- If a company has received or is about to receive the maximum amount of aid, or if the company is a company in difficulty in accordance with the De minimis Regulation, it may be prevented from receiving the aid or the aid may require a higher financing price, i.e. so-called pricing without including aid.
- The maximum level of de minimis aid is monitored at the so-called single undertaking level defined in the Regulation. The company is responsible for ensuring that the maximum amount of de minimis aid paid by different parties is not exceeded. If the maximum amount is exceeded, the aid may be recovered in full and with interest.
- Finnvera’s financing for investments may include project-specific investment and employment aid granted by the EU to SMEs (so-called SME aid).
- In addition, Finnvera can use the SME Rescue and Restructuring Aid Scheme that is suitable for financing enterprises in difficulty.
In connection with each financing decision, Finnvera checks whether the financing can include imputed State aid or not and selects a form of aid that may be suitable for the case.
Publication of de minimis aid information from 1 January 2026
The obligation to publish de minimis aid information has entered into force on 1 January 2026. In Finnvera's case, the publication obligation concerns financing decisions made on or after 1 January 2026 (new financing and changes). The following information will be public: the beneficiary’s name, business ID, the amount of aid granted, date of the decision, and the provider of the financing. In practice, the publication obligation only means registering these individual pieces of information in the aid register. The register can be found here: European Commission’s de minimis aid register.
In all other respects, Finnvera’s client data will continue to be secret.
However, due to state aid regulation, export guarantees must always be priced in a way that they do not include any aid. Further information about state aid on MEAE website.
For more information on de minimis aid and the publication of aid information, see the FAQs. Read FAQs about de minimis aid
Confidentiality of operations
Finnvera is committed to confidentiality in its operations. This is how confidentiality is respected regarding client and insider information as well as data protection and information security.
Prevention of money laundering and terrorist financing and compliance with sanctions
Finnvera complies in its financing activities with anti-money laundering and sanctions regulation as well as applicable government authority guidance concerning customer due diligence obligations. The objective is to ensure that funds obtained from illegal sources are not transferred through Finnvera into the financial system and that financing granted is not used to fund criminal activities. Through its customer due diligence obligations, Finnvera also seeks to contribute to ensuring compliance with international sanctions.
Customer due diligence obligations include verifying the identity of the customer and any person acting on behalf of the customer, identifying the customer’s beneficial owners, collecting information on the purpose and intended nature of the customer relationship, and recording customer information. Customer relationships that involve a high risk of money laundering and terrorist financing also require enhanced review measures and additional documentation.
In order to fulfil its customer due diligence obligations, Finnvera primarily requests the necessary information from the customer in connection with application processing and during the customer relationship in order to update the information. Finnvera may also supplement and verify the information using data available from official information sources. Ultimately, if Finnvera detects an unusual or suspicious transaction concerning a customer, Finnvera must apply its duty to investigate and, where necessary, report the matter to the Financial Intelligence Unit.
Finnvera’s policy on the prevention of money laundering, terrorist financing and sanctions, approved by Finnvera’s Board of Directors, sets out the key requirements for the prevention of money laundering and terrorist financing and for compliance with sanctions. These include, among other things, the following areas:
- identifying and verifying the customer, the customer’s representatives, beneficial owners and other parties material to the financing;
- understanding the customer’s business, ownership structure, financing need, the project to be financed and the use of funds;
- assessing money laundering, terrorist financing and sanctions risks related to the customer, project, sector, geographical connections and other relevant factors;
- applying appropriate due diligence measures based on the risk assessment of the customer and project, including enhanced additional checks where necessary;
- taking sanctions risks into account in customer due diligence, financing preparation and contract management;
- investigating, assessing, escalating and, where necessary, reporting unusual, unclear or suspicious findings to the Financial Intelligence Unit;
- ensuring that customer information is up to date, that the customer relationship is monitored, and that due diligence, risk assessment, sanctions screening and additional investigations are documented;
- providing personnel with guidance and training and defining clear roles and responsibilities.
Finnvera is committed to identifying, assessing, preventing and managing the money laundering, terrorist financing and sanctions risks related to its activities on a risk-based basis. Finnvera has no risk appetite for situations in which it is unable to fulfil its obligations concerning the prevention of money laundering, terrorist financing or sanctions. Finnvera does not establish or continue a customer relationship or grant financing if the customer or key parties cannot be sufficiently identified, if the information provided is incomplete or misleading, if there is a justified suspicion that the transaction involves criminal activity, money laundering, terrorist financing or sanctions circumvention, or if the risk cannot be acceptably investigated and managed.
