Thomas Grahn is the founder and leader of the firm AML Consulting and he works since 1 July 2006 as an independent consultant in the field of anti money laundering (AML) and the countering of the financing of terrorism (CFT) as well as in related areas as criminal and financial law, operational risk management, internal controls etc.
Since the launching of AML Consulting, Thomas Grahn has been assigned for various projects, reviews and other consultancy tasks for banks, other credit institutions, stock brokers, life insurance companies, money remittance service providers, state authorities, financial industry bodies, audit firms, IT-companies and education & training providers. Thomas Grahn has also on a number of occasions been assigned as speaker and chairman at seminars and workshops in i.a.Belgium, Bosnia-Herzegovina, Bulgaria, Cyprus, Estonia, FYR Macedonia, Georgia, Israel, Jordan, Croatia, Moldova, Nigeria, Serbia and Turkey which were arranged by the European Commission (EC) technical assistance programme and others. He was also assigned for a longer term EC-funded project in China during 2006 for the development of a comprehensive AML e-learning tool in co-operation with other experts.
Thomas Grahn has a background as a regulator at the Swedish Financial supervisory Authority, Finansinspektionen (FSA) and was in that capacity for many years responsible for AML issues. Thomas Grahn has also during his term at FSA been involved in measures against financial crime in a wider sense, operational risk management, internal controls, and certain legal issues within the FSA competence area. From October 2001 he was also designated to exercise the similar functions at the FSA as regards the area of CFT.
Thomas Grahn was during his stay at the FSA i.a. responsible for the development and implementation of supervisory techniques and practices in on-site and off-site supervision of financial institutions on AML issues including supervision on consolidated level as regards Swedish institutions with business abroad and in recent years also supervision on CFT measures and financial institutions’ handling of sanction lists. He has also participated in on-site missions covering other areas as corporate governance and internal controls, operational risks etc.
Thomas Grahn has also been responsible for the drafting of regulations and general guidelines within this area, i.a. the 2005 edition of FSA Regulations and General Guidelines on AML/CFT (FFFS 2005:5). On the subject of regulations and guidelines he has led many meetings and discussions with a wide range of financial institutions and industry bodies regarding the interpretation of the rules and the formulation of policies and internal instructions. He has also been representing the FSA in working groups with other national stake holders as the Financial Intelligence Unit (FIU), The National Economic Crime Bureau, the National Council against Economic Crime and the Committee on the Certification of ID-cards as well as with the relevant financial industry bodies.
Regarding policy and legislative issues, Thomas Grahn has been a member of four Government Commissions through the years, including the Committee on the revision of anti money laundering legislation, legal and regulatory aspects of so called electronic money and issues regarding the responsibility for misuse of credit cards. He has also on a regular basis been drafting responses and comments on proposals, bills, reports and other policy matters on AML/CFT addressing the relevant government ministries and authorities.
On the international level Thomas Grahn was during his stay at the FSA member of the Swedish delegation at the Financial Action Task Force (FATF) for about twelve years and also representing Sweden in various FATF working groups and mutual evaluation teams. He has also been representing Sweden in the EC Contact Committee on money laundering and other EC groups through the years. Furthermore Thomas Grahn has participated as a national expert in various seminars and workshops organised by the EC Phare and Taiex technical assistance programs as well as similar types of events organised by the Council of Europe and the UN.
He has also since many years been holding courses on the subject of AML and related and been a key note speaker on a number of conferences and seminars.
Thomas Grahn is also a co-author of a book on "Measures against money laundering and the financing of terrorism - a practical guidance and legal commentary" published by Norstedts Juridik, www.nj.se (in Swedish only).