The Silent Gatekeepers: Why Nordic Lawyers Aren't Filing Suspicious Activity Reports

An opinion piece published on April 24 in Finansavisen pointed out a striking imbalance in Norway's anti-money laundering reporting system. While Økokrim's Financial Intelligence Unit received 33,313 suspicious transaction reports last year — a 9 percent increase on the previous year — lawyers sent  24. Twenty-four. That's 0.07 percent of the total.

Even more telling: only three of those 24 reports came from one of Norway's 25 largest law firms. The firms handling the most complex transactions, the highest-value deals, and the most intricate corporate structures — precisely the work where money laundering risk is highest — are producing almost nothing.

This inspired me to look at the larger perspective here. This is not just a Norwegian phenomenon. Across the Nordic countries, the picture is remarkably similar.

In Sweden, Finanspolisen received 56,136 SARs in 2023 — a 24 percent year-on-year increase — with negligible contribution from the legal profession. The situation is similar in Denmark. 

The numbers across all three countries tell the same story: a profession consistently rated as high-risk for money laundering exposure, consistently producing almost no intelligence for the authorities.

The structural picture

To understand why reporting is so low, it is instructive to to look into the structure of the profession itself. Because not all lawyers are equally exposed to AML risk — and the structure of the industry matters more than the raw headcount suggests.

Norway has over 6,000 lawyers and 1,800 associate lawyers, spread across roughly 2,000 firms. But the distribution is heavily skewed. Around 1,467 firms are solo practices. At the other end, the five largest firms account for 29 percent of the profession's total revenue. The top 40 firms — just 2 percent of all firms — generate 68 percent of all revenue.

In Sweden, the Bar Association has approximately 5,500 members. Almost 60 percent describe business law as their main field. Criminal law accounts for 36 percent. Family law and other individual-oriented practice areas are in decline.

Denmark has approximately 7,600 lawyers, with a similar concentration of commercial work in a handful of large firms — Kromann Reumert, Plesner, Gorrissen Federspiel, Bech-Bruun — alongside a long tail of smaller general practices.

This matters because AML reporting obligations are triggered by transactional work: corporate deals, real estate, company formation, financial structuring, trust and estate management. Criminal defence, family law, and litigation are largely outside the scope of the reporting duty. So the relevant population is not the full profession — it is the segment doing commercial and transactional work.

And that segment is overwhelmingly concentrated in the largest, best-resourced, most sophisticated firms. These are firms with dedicated compliance functions, hundreds of lawyers, and billions in annual transaction value flowing through their practices. If anyone in the legal profession should be encountering and reporting suspicious activity, it is them.

Which brings us back to Norway's 2025 numbers: three reports from the top 25 firms. Three.

Why so few reports?

Several factors help explain the gap, but none of them fully excuse it.

The long tail of small firms. A large share of the profession — particularly solo practitioners and small general practices — does relatively little transactional work. Their day-to-day practice involves legal aid, criminal defence, family disputes, immigration, and other areas that fall outside the core AML reporting scope. It would be unreasonable to expect high SAR volumes from a sole practitioner handling custody cases in Tromsø or divorce proceedings in Vejle. This is a genuine structural explanation for part of the low numbers — but only part.

The privilege tension. Lawyers operate under a professional obligation of client confidentiality that sits in direct tension with the duty to report. The FATF Standards carve out explicit exceptions for legal advice and litigation, and the AML legislation in all three Nordic countries does the same. But in practice, the exception tends to swallow the rule. In Norway, the Bar Association once argued the exception was so broad that lawyers effectively had no reporting obligation at all — a position the Financial Ministry had to formally reject. In Sweden, academic research documents how lawyers adopt what researchers call "practices of separation" to minimise the discomfort of policing their own clients.

Risk perception. Research on Swedish lawyers' attitudes to AML found that they largely position themselves as knowledgeable actors who can assess and manage risk — and who distinguish themselves sharply from banks. The attitude that "we are not banks" serves as a justification for a lighter approach. But client funds accounts, complex corporate structuring, and cross-border transactions make commercial law firms uniquely positioned as money laundering vehicles. Sweden's Finanspolisen put it bluntly in a 2024 report: lawyers' client funds accounts can be used to conceal and integrate the proceeds of crime, and lawyers who act as professional money launderers pose a "particular threat to society."

What we still don't know — and what needs to change

The debate around lawyer SAR reporting tends to oscillate between two positions: either the profession is fundamentally failing its obligations, or the low numbers are an function of most lawyers doing non-transactional work. The truth is probably somewhere in between — but we don't have the data to say where.

What we need is a much more granular understanding of where AML risk actually sits within the legal profession's structure. We know the overall numbers are low. We know the largest commercial firms are barely reporting. But we don't have a clear, public breakdown of how many lawyers in each Nordic country are actually doing the type of work that triggers reporting obligations, what their risk exposure looks like, and how their internal compliance processes function in practice.

This matters because the policy response depends entirely on the diagnosis. If the problem is primarily one of awareness and training among smaller firms that occasionally handle transactions, the solution is education and guidance. If, as the numbers suggest, the problem is concentrated among large commercial firms that are structurally exposed to high-risk work and yet producing almost no reports, the response needs to be significantly more forceful — better supervision, meaningful sanctions, and a willingness to challenge the current self-regulatory model.

Being a banker and not a lawyer, I will refrain from easy solutions.  But the times are not on the side of blind regulations. Many voices opinions that European over- regulation is holding back economic and societal development. 

All the more reason to start thinking a regulation that more clearly differentiates on risk. The incoming EU AML framework — AMLA, the AMLR, and continued FATF pressure on gatekeepers — creates an opportunity to move away from one-size-fits-all supervision of the legal profession. A solo practitioner handling legal aid cases does not pose the same risk as a top-20 firm advising on cross-border M&A, complex corporate structuring, and high-value real estate. Supervisory attention and expectations should reflect that. The largest commercial firms — the ones managing the most complex clients and the highest transaction volumes — should face the most rigorous oversight, the clearest reporting expectations, and meaningful consequences when those expectations are not met.  

Sources for this article include: EFE/Økokrim statistics; Finanspolisen Annual Report 2023; Finanspolisen, "Professional Money Launderers" (2024); Norwegian Bar Association industry statistics (2022–2023); Swedish Bar Association member surveys; FATF Horizontal Review of Gatekeepers (2024); Norway National Risk Assessment 2022.