Finland's Financial Supervisory Authority imposes EUR 1 million combined penalty payment on Alexandria Group for investment advice suitability and internal control failures

Finland's Financial Supervisory Authority (FIN-FSA) has imposed a combined penalty payment of EUR 1,000,000 on Alexandria Group Plc for omissions in the client information required for providing investment advice, the retention of that information, and the establishment of an internal control mechanism. The omissions relate to the periods from 1 March 2021 to 30 September 2021 and from 11 May 2021 to 30 September 2021. The FIN-FSA found that Alexandria Group Plc did not obtain all legally required client information before providing investment advice, including sufficient information on clients’ knowledge of investment products, the purposes of their investments, and factors affecting their capacity to bear losses. Recordkeeping was also deficient, including failures to record information collected on clients’ understanding of basic investment concepts and information used to determine the client’s risk profile. Shortcomings were also identified in internal control arrangements, including mechanisms for addressing and monitoring deficiencies, audit work instructions for the investment advice process, system-technical monitoring of investment advice, and the detection of unlawful activities. The findings arose from a FIN-FSA inspection conducted in 2021–2022 focusing on suitability assessment in investment advice provided via tied agents. The decision is not yet legally binding, and Alexandria Group Plc may appeal to the Helsinki Administrative Court within 30 days of receiving notice of the decision.