Hello, and welcome to today's Swedbank announcement. Throughout this, all participants will be in a listen-only mode, and afterwards there'll be a question and answer session. And just to remind you, this is being recorded. So today I'm very pleased to pass you to Gregori Karamouzis, Head of Investor Relations. Gregori, please begin.
Thank you, operator. Good afternoon, everyone, and thank you for participating on this call with such short notice. Due to today's Swedish media coverage on money laundering related matters and Swedbank's mentioning in this context, we would like to make a few comments. I will soon hand over to Birgitte, but after Birgitte's comments, we will open up for questions. Birgitte, please.
Thank you, Gregori, and thank you for joining us. It's been quite a dramatic day. But first of all, I would like to start off by repeating some of the key messages that we have conveyed to you before. Nothing has changed in that. Swedbank has a domestic business model that focuses on local, private, and corporate customers in all our home markets. We have and have always had a very systematic approach to dealing with all kinds of economic criminal activities. We have a zero tolerance. When we have identified suspicious transactions or suspicious activities of any kind, we have acted by conducting in-depth reviews, and where appropriate, we have reported them to the authorities, which is the finance police. We have a very low share of non-resident customers in the Baltics.
As you know, it's around 1% or a bit more, 1.5% on average. The majority of these are private customers, and in addition, we have, throughout the years, had a very small number of non-resident corporate customers domiciled outside of the EU. It was actually 79 individual customers last year. In Estonia specifically, the share of non-resident customers out of total customers is around 1%. I will say this because this was a topic that you, many of you referred to when we had our last call, which was in combination with just before the third quarter, and something we've talked about.
You've also seen, and we've shared with you the information that came out of the Estonian Central Bank about our cross-border payments, which is an indication of what kind of business you run, that in Estonia, they are predominantly executed within our home markets, cross-border payments that go to the other countries where we operate, which is Sweden, Latvia, and Lithuania. Also, when you look at the amount of cross-border, they are in line with the corporate banking business that we have in the country, and it has been very stable over time. I would also like to clarify to everyone in relation to a Swedish news program that will be broadcasted tonight, but it was released on the Swedish Television, their website this morning. This was on AML.
In general, it was connected to the Magnitsky case, but also very much Danske and to Swedbank. And, for many reasons, I think because we are the largest one in Estonia, so we were included in this. And in connection with this, I would like to say that something that you're all aware of, but still it serves a purpose to repeat it. Money laundering attempt and other types of economic, criminal, criminal activities that try to make their way through the banking system, including Swedbank, is the largest challenge for banks overall. It's something, it's a phenomena that happens cross geographies, customer groups, and segments, not only in the financial sector, but it happens in all banks. When we in Swedbank identify suspicious transactions, we take action, we conduct more thorough investigations, as I said, and where needed and appropriate, we report it.
So also, as we've mentioned to many of you already, during the past 10 years, the activities have changed shape and form as the regulation regarding AML has developed and our own internal processes and approach has been strengthened, and we act in a way that is helped by our monitoring systems in reply to all the suspicious transactions. So at various points in time, we've taken actions by actively off-boarding customers that no longer fulfill our requirements. As we mentioned in October, we, when Danske blew up, so to speak, on top of the fact that we have been monitoring suspicious activities continuously for a long time, we've also initiated a look back, which I talked about to many of you, analysts, investors, and also in media.
And in this look back, what we did was that we talked to, we took in external help. We thought that it was good and useful for us to get external eyes on our own systems and everything that we found. And we used risk indicators on transaction data between Danske and Swedbank between seven and 15. And we concluded that what we saw, we acted on. And I think that this is important to repeat, that there's nothing new. I also had questions today that when Danske first hit the media, there was a number of customers, a small number, it was six or seven mentioned. And upon a question from media, I replied that none of these are customers of Swedbank. That still holds.
Since October, we've taken further actions. We continue to work with this. We continue to do deep dives into things that we see, and that is actually not nothing out of the ordinary as such. I would also like to mention that today in Swedish media, there has been mentioning of Bill Browder, who is kind of the Magnitsky case, that I'm sure that you all know about, which is a completely horrible case, all of that. Awful in all aspects. And what I would like to share with you is that, and I think I said this to many of you before, that we understand in Swedbank that we don't know it all.
So we look to the outside constantly to get help, to see if there are indicators, counterparties, or traffic that we haven't detected ourselves. We work with other banks, we work with authorities, and we work with, yeah, we screen media for things, et cetera, and we apply all that to our own systems to make sure that we actually go. And in connection with that, I went to London and met with Bill Browder and asked him to share what he saw. Because I think that it's important for us to reach out to everyone who works with money laundering and who have detected things, just to make sure that we have seen the same thing. And that, I think, could be important information in relation to what was in...
Because there's been a piece of news in the newspaper today that he might come in and sue Swedbank. And we actually talked to him today, and there's no such thing. So I think let me just end here, and then I think we move on to take questions.
Thank you, Birgitte. Operator, we're handing back to you to let the questions through.
Thank you very much. So, ladies and gentlemen, if you wish to ask a question, it is zero and then one on your phone keypad now in order to enter the queue. And then after I announce you, simply ask that question. And if you find that question has been answered before it's your turn to speak, just press zero and then two to cancel. And our first question is from the line of Rob Raine of Kepler Cheuvreux. Please go ahead, sir. Your line is now open.
Hi, and thank you for taking the question. So I understand that you have seen the material of the journalists, and I understand that you cannot comment on individual cases, but are these figures new to you, or have you already reviewed this material before?
Hi, Gabriel Francke Rodau, Head of Group Communication. We have not seen the full material from Swedish Television. They showed us some material, but not all.
All right. Okay. So is there any reason for you to believe that there might be individual Swedbank employees that have committed crimes, as seems to be the case with Danske Bank?
Of course, that's part of our usual sort of due diligence. We track this too, and we haven't seen anything.
All right. Thank you. That's all.
We are now over to the line of Mats Liss at Handelsbanken. Mats, please go ahead. Your line is now open.
Yes, good afternoon. A couple of questions, if I may. First of all, you mentioned that you have had taken in external help or an independent investigation. Is that something that you could share? I know you can't specify details, but could you go through, share maybe the conclusions of it? Because I think that will help us a lot in understanding, building the trust of, of Swedbank in the market. And also, further on, I know that the Swedish FSA has commented earlier that they saw no risk in the Swedish banks. Is there any way you could get a general comment on the banking society or something from the FSA or any regulator? And then finally, you mentioned that systems and procedures have been strengthened in the past years.
But if we look or see the article or, or report today, they are blaming from 2007 to 2015. Is there any risk that there's been payments that took place in, like, 2007, 2008, that could have slipped through the system that were in place by that time? Because I guess it was more lax than, than what we have today. That's all for now. Thanks.
If I can ask your last question first, was there any risk that a payment in 2007 could have slipped through? And, yes, there is a risk. But, and that was one thing. And, but it's right, of course, that we work with processes and procedures, and we've developed immensely over the years. And when we took in the third party, this is more, they actually confirmed what we're doing, which was, which was very good for us. And, there was nothing sort of really that they saw that we, we hadn't seen or anything. So, so that was, that was good. And then you asked about the FSA.
We've been in contact with all FSAs, and, as you may have seen, the Estonian, Latvian, Lithuanian FSAs all came out with press releases commenting on the way that they work. And, so the strength of the system as such. We also talked to the Swedish FSA, and I think that they have been conducting investigations over the years, which has been thorough and in-depth. We are covered, as you know, by the Baltics in the Baltic countries and by the Swedish FSA in Sweden. But they share their findings with each other, and we also share everything we can with all FSAs. This is important to us.
But there's nothing that you could share with us to sort of, I mean, we see credit spreads moving today, and if we could get some more details, I think it would be supportive.
No, I'm sorry.
Okay. Okay, thank you.
Okay, we are now over to the line of Merilin Pärli at ER, Estonian National News. Please go ahead. Your line is now open.
Thank you, and good afternoon. So, do you claim that the facts about the Swedish TV station wrote this morning are lies, or is any of it true? Thank you.
I don't claim that it's lies at all. What I'm saying is that it's very difficult for us to comment on it, as we haven't seen. We don't know. We haven't seen the material. We haven't seen the list of, clients that they're talking about. We haven't seen the transactions. So, so it's, it's really, really difficult for us to comment on it. So this is what we are saying and then why we're having this call. And is that, you know, what we can do is that we can reiterate how we work with it and what we see and how we work with, with others, et cetera. But we can't really say anything about this, as we don't know.
Thank you.
Okay, our next question is over to the line of Riccardo Rovere at Mediobanca. Please go ahead. Your line is now open.
Thanks, thanks for taking my question, and good afternoon to everybody. One follow-up, if I may. Getting back one second to the external support that you got, that you got to look at the past transactions. Is it possible for you to share with us, since what year, the external support started looking into past transactions? Is it past two years, past three years, past 10 years? Is it possible to have an idea on that?
No, but, you know, Ricardo, what we did was, we've done it several times over the years. You know, where we, when we've seen something that we found was very complex or where there were certain patterns that we needed to understand better, then we've never been stingy on looking to the outside and get more help in understanding, because it's been so important for us to act on everything we see. And the Danske thing we did when Danske exploded in, you know, after the summer. But that was sort of on top of the monitoring and what we'd already done for years.
Okay, thanks. And what -- if I may, maybe it's a naive question, but let's assume you see something suspicious. You proceed with the transaction, but you report the suspicious transaction. Sorry for the naive question. Are you doing anything wrong once you have reported it to the various authorities, to the police, to the whoever need to know?
No, this is exactly how we work.
Okay.
We are completely-
Once you report it, you have fulfilled your duties. Do I get it right?
Yes, you do. But there's a second part of it, and that is we also act. When we see things, we report it, but we also ask customers to leave the bank. So we off-board customers, and this is an important part, too. We, we sort of we look at everything, and then we ask them to leave the bank.
Okay. Okay, thanks.
Right. So we're now over to the line of Jan Wolter at Credit Suisse. Please go ahead, Jan, your line is now open.
Thanks. Hi, Jan Wolter, Credit Suisse. And a couple of questions then. First, I think a key question is, how much of the suspicious transactions have already been reported by Swedbank as such? And if not today, but it would be, I think, helpful if you could reveal the aggregate data on how much over the years have been reported in regards to the Baltic operation as suspicious flows. I think you can definitely reveal that aggregated data. Banks have done that across the globe. So first question is really if you can shed any light on that on today's call, or if you can do it perhaps later. The second question is, I think you highlighted that you've seen some, but not all material of the broadcaster.
And the question is, excuse me, has Swedbank identified the same 50 clients that SVT has identified? And if you haven't gotten the names of these clients, will you ask for the list? Because that would be a natural starting point not to do, having the broadcaster has highlighted that they would be willing to give you the materials. So that's the second question. And the third one is, I think you mentioned that the Baltic non-recip portfolio was 1% of deposits in Estonia. Just if I could, if you could reiterate that, if that's correct or not. And then, what's the size of the total non-recip portfolio, between 2007 and 2015, so we get, we can gauge how big it was during those more sensitive years. Thanks a lot.
Okay, Jan, Jan, I'll just try to. I think that on your, on the numbers, I will just refer you to the documentation that we send out in connection with the third quarter, because you have all the numbers in there. You see exactly both volumes, you see number of clients, et cetera. All of that is in there. On the question of the document with the 50 customers, we don't know. We haven't seen it. We didn't get the list. And also, when I get these questions, you know, some say, you know, maybe they mention names of a couple, but we can, of course, never say yes or no.
But it, the fact that the, that there might be clients on this list that might have been customers of Swedbank, there might have been customers that we have found, we have reported, and we have off-boarded. There might also have been customers that came in with one business model that changed into different business models, so we off-boarded them. We saw this. But we can't say, because we don't have the names, and if even if we had, we could never comment, and you know that well. Then also, what we, report to the FIU, the police, we report suspicious activity. We don't report amount, and we actually report everything.
Sure, if I could just follow up. So if you don't have the list with these 50 clients, will you ask for it from, from the broadcaster in order to check against your own list and how many, what proportion are red flagged? Because I think you can do that and then also tell the market whether or not you, you, you have already identified those as, as sensitive clients or red flagged clients, please.
Hi, Gabriel here again. All the information that can help us, we ask for.
Thank you. The final one for me is, I think, Birgitte, you said that Bill Browder, you've spoken earlier and or today, and that he will not make a claim against Swedbank or sue Swedbank. Did I get that right? Or what are you saying about or what did he say to you? Thank you.
Yes, you got that right.
Okay, thanks a lot for that, for those clarifications.
Okay, we are now over to Paulina Sokolova at Barclays. Please go ahead, Paulina, your line is now open.
Hi, thank you for taking my question. I just have one left, actually. Just going back to 3Q, I think you mentioned that you did not have any of the names in the Danske Bank report as clients. Could you maybe elaborate on, you know, what you meant by that comment and whether you think this is still the case? Thank you.
These were clients that were out in media when all this came out initially.
Okay, so how many clients approximately? Was this the six or seven clients you referred to earlier, or is it a much more expansive list?
No, it was what you said. I think it was seven. Yeah.
Okay, thank you.
Right. We're now Jacob Kruse at Autonomous. Please go ahead. Your line is now open.
Hi, thank you. So I guess most of my questions have been answered, but just to get back to the scale here. So the Swedish press is saying they look at a subset of what you do, they look at 50 clients, they focus on where there have been transactions between yourselves and Danske, and they come up with this number of $5.8 billion. And from this call, it sounds to me like you're saying we can't really know what those transactions are, but we have been continuously reporting. But just... And I know you don't, you say you don't actually collect the sort of reported volumes, but that $5.8 billion number, which I guess if they had access to all your data, they could probably find additional on the same basis.
Is that a similar number or is that the same ballpark of number as to the level of transactions or the level of activity that you would already have report to your authorities?
You know what? Frankly, we don't recognize this number. But if you look also back at the documentation that we gave you in connection with the third quarter, you see very clearly our cross-border. You can see that, how much we've had, you know, annually, for everything we do. So, do that. Maybe Gregori wants to add something.
Yeah, and you can see there, Jacob, on the slide that we present in conjunction with the Q3 report, that we have had volumes in terms of cross-border, outgoing cross-border transactions, payments in Estonia of between SEK 10 billion and SEK 15 billion per year. And the growth in that number has been in, you know, in line with the economy. So then you can make your own, your own comparison to the number that's been in media.
That's been everything.
Right. To get to that $5.8 billion, you would have had to have reported effectively a tenth of aggregate transactions? Or some—I guess it seems like a fairly big number, in compared to the numbers you're mentioning now, that you presented on the previous slide.
Yeah. Yeah, I mean, that is your conclusion based on the numbers. If that 5.8 is a real number, then that is a conclusion you can draw. But we report what we... The transactions that we have and what we see, and that's the numbers we gave to you in conjunction with the Q3 report.
Have you said how many suspicious activity reports you have filed?
We have mentioned that the number in the Baltics on an aggregate level has been around the same number as the one in Sweden in the most recent years. So it's a couple of thousand reports typically that you will see on an annual basis.
Okay, great. Thank you.
Okay, before we go on to the next question, which is Chris Thompson at Reuters, can I please remind everyone that so we can get through as many questions as possible in the time allowed, can you please not rejoin the queue for follow-up questions? And Chris, over to you.
Oh, hi there. Thanks for taking my questions. Just two very, very straightforward ones. Firstly, are you currently in any contact whatsoever with authorities in the U.S., concerning this? And secondly, you mentioned that non-resident accounts accounted for about 1% of your Estonian clients last year. But what about the period in question between 2009 and 2015? Did they non-resident accounts account for a higher proportion during the period under investigation? Thank you.
No, we are not in contact with the authorities in the U.S. at all.
And sorry, the second part of the question I didn't catch. Could you just repeat that?
Sorry. It was at the beginning, you mentioned that non-resident accounts are about... Constitute around 1% of your Estonian client base last year. But I was just wondering, the period under investigation is 2007 to 2015, what roughly was the average proportion of non-resident accounts in your Estonian subsidiary during that period?
In terms of customers, again, we have given you the data, and the aggregate number has not changed a lot. What we have seen is that the private part has increased lately, and that has to do with labor, with work, you know, people moving into or working in Estonia. That's why we're seeing a slight increase of individual customers.
Okay. Thank you.
We are now over to the line of Maria Ignatyeva, of, Novaya Gazeta. I do apologize if I've mispronounced that, but please go ahead, Maria.
Good evening. Thank you for taking my question. I also wanted to ask about this non-residents portfolio. I am wondering which part of it are non-residents from Russia? And, another question is whether in this period of time, between 2007 and 2015, you have recorded any suspicious transactions, in particular, related to Russian clients?
So the first question was about Russia specifically and Estonia, if I understood it correctly, is that right?
Not only in Estonia, in all countries where Swedbank operates.
Yeah. The majority of the non-resident customers are EU domiciled, and then there is a portion of former CIS countries and other countries, but the majority is EU, and then there is an even split on the other categories. So there is some Russian domiciled, or, you know, customers with Russian citizenship.
Okay. And, the second part was whether you have recorded any suspicious transactions related to those clients that are non-residents and that are from Russia in this period of time, between 2007 and 2015.
We don't have that information available currently. I think the country per se is not really what we're looking after. We're looking after the activity, the type of activities and the type of customers. So I cannot exclude it, but I cannot confirm it either.
Okay. Thank you.
We're now over to Richard Smith at KBW. Please go ahead. Your line is now open.
Yeah, thank you very much for the call. Just one quick follow-up from me, just on your comments around having been in contact with Bill Browder. And I guess you've requested information from him. I mean, firstly, was there sort of anything that he provided, and was there anything that you felt from the information that he gave you that was substantially different to what your own systems were picking up historically? Thanks.
No, there was nothing that was significantly different from what we have seen before. But, I can tell you it's always useful to have these discussions, and I highly appreciate it when, when I have it. It can give different context, et cetera, and I think that that is very, very important.
Okay, thank you.
We now go to JP Morgan Asset Management and Steve Sung. Please go ahead. Your line is now open.
Hi. Yes, thanks for taking my call. I want to get back to your non-resident portfolio. You're disclosing around 1%, are non-resident, but this percentage to me is not really helpful. Can you disclose the number of accounts in both corporate and private, outside non-resident, you know, in EU and outside EU and in, you know, Russia and the CIS, just number of accounts? And then what is the transacting amount involved every year over the last seven years? I mean, obviously, you have the data behind it when you provide all this percentage, but we want to know the real data. Thanks.
In terms of the deposits, we haven't specifically given that number because we don't think it's a relevant number. It's because deposits are typically money that's, you know, sits on the accounts, but it's rather the transactions that we are tracking and following. That is one comment. And then when it comes to the actual, you know, transactions, as I mentioned before, since most of the non-resident customers that we have are domiciled within EU countries and also private individuals, the transactions that are conducted are primarily done within our home markets, so within Sweden and the three Baltic countries. But of course, there are other European countries in these transaction flows as well.
I'm sorry, so why do you think the disclosure of number of accounts is not relevant? To me, that's, that's really relevant, and I want to know, do you have 60,000 corporate accounts like domiciled in Malta, that have made hundreds transactions over one year?
We've given you the number of non-resident corporate customers. Birgitte mentioned that, and it was a low as low number, 79 customers last year, and that number has been low throughout the years, and that is across the Baltic countries. So that gives you some indication of these type of customers, which is a very small number.
Okay, thanks.
Okay, we now go to the line of Jan Almgren at Svenska Dagbladet. Please go ahead, Jan. Your line is now open.
Hello and good evening. I just wonder a little bit, what's your feeling about all this new information about money laundering? Is it something that worries you? Is it a problem, or it's just business as usual today? My second question is, what do you say about Mr. Bill Browder's demand to start a new external investigation around all this? Is that something that you are planning to do? Thank you.
Yeah, you know, it's a very good question, your first one. And it's, of course, we take this really seriously, and we do everything we can here to provide as much information to everybody who asked us, internally and externally today. But basically, I come back to what I've said before. I'm very comfortable with the way that we work with these issues. And we've been working through the years, and I see how we, yeah.
So basically, we continue to do look backs, we continue to do more investigations, we continue to report, and we also continue to talk to as many people who can help us as possible, and to take in experts when we hear about people outside who can come in and help us with doing analysis or a different view at this. Because we also know that criminal activity, which this is, it's finding new ways all the time. So we have to be on our toes constantly to detect where there are new patterns, et cetera. And you know what? I haven't seen this thing about Bill Browder requesting a third. I don't know. I don't know. I'll have to come back to you on that.
Whether you are planning to do that or not?
Today, no, we are not thinking about doing anything more than we are already doing.
Okay. Because I, I spoke to Mr. Bill Browder just an hour ago. He, he said that, that was one of his demands, that, that the bank should start some kind of new external investigation.
Mm-hmm. Yeah, you know, let me take that with me, and, but, yeah.
Okay. Just one last question. What, what's your main message to customers today after all these big headlines? What's your comment? What, what's your message to them?
You know, my message is that I understand if you've seen this program. I understand very well that you can think that it's, did this really happen? And this Magnitsky case is so horrible, and there's so many dimensions to it. It's very complicated, and it's a tragedy in all respects. And also, when you see this, they talk about things, the customers and things that have come through Swedbank, and I can understand that you can, you know, think, you know, is this, you know, what has happened in the bank? And what I can do is that I can continue to reiterate that we do everything we can, and we do it constantly. We are a big retail bank.
We are not a bank that focuses on a small number of non-resident customers that have a specific business model. We're a big retail bank in all countries. We work with mortgages and payments and cards and pensions and corporate banking, et cetera. We take this extremely seriously. We work so much with government and with everybody. We work with governments in all three Baltic countries in order to strengthen infrastructure. So it's not we work with it a lot internally in Swedbank, but we also work with, yeah, government, politicians, prime ministers, et cetera, in order to strengthen this, because it's an important part of the confidence issue in banks, which is a bit away, yeah, today. So it doesn't feel good at all. I can tell you it doesn't.
At the same time, you don't say that some of the information, some of the figures or numbers in the program is wrong.
It's impossible because we don't know. We haven't seen all of it, so, you know, I can't say it, you know.
Shouldn't you know?
What?
Shouldn't you know?
Not, yeah, I got that.
Yeah, I think I told some of your colleagues. We have, we have seen the number, that it's 50 customers, that it's SEK 40 billion. But we have not seen any specific details. e.g., names of the customers on the list.
Okay. Thank you very much.
Okay, our next question is from the line of Benjamin Segel at Neuberger Berman. Please go ahead, your line is open.
Hi, good afternoon, and thanks for doing this call. You make the case, which is good to hear, that anti-money laundering disciplines have improved over time, and clearly, this is gonna be a focus over the next few years for everybody in the industry. My question is, you had a process in place during the period under review, and you would have flagged some transactions, I think you said a couple of thousand, both from the Swedish subsidiary, but also a similar number from your non-Swedish Baltic operations. My question is, as you look back and you went over the data prompted by the Danske Bank story. Were there any additional transactions that you reported after the fact under a new stringent, strict, and improved reporting system? Or is the transactions you reported only the ones that you reported at the time?
You know what? I'm not gonna answer your question directly, but what I can say is that as we see things, we act, and that goes for everything. So there might have been things that developed over time, that started off as being okay, and then developed into something that we didn't like, and then we acted on, forward it, and reported to the police.
I guess the reason I'm asking is because it's one thing not to catch bad behavior, which is one thing, and we all recognize that the safeguards have improved over time. It's another thing to have sort of spotted them, but not sort of reported them. Are you saying, and you've certainly implied that anything that you've seen, either at the time or with your subsequent reviews, with third parties and even yourselves, you have proactively reported, even if it was for transactions that might have slipped through at the time? Is that... Can you confirm that anything you saw, at whatever time you saw it, was reported? And so you've done everything you could possibly expect to have done, as of when you knew the information.
Clearly, if you were a clairvoyant, there might have been other things you could have spotted, but everything you did spot was reported.
Yes.
Thank you.
Okay, we now go to the line of Conor Middleton at JP Morgan. Please go ahead. Your line is now open.
Hi there. Yes, thanks for taking my questions. Just firstly, I was wondering if you could give us a bit more color on the actual processes that you have in place in the Baltics in order to monitor this kind of risk. I think if I understood the program correctly, they mentioned about 1,000 customers with accounts outside of the Baltics. And so I'm just trying to kind of figure out the checks that you have in place to kind of ensure that these are legitimate customers. And then the second question is: when you say that when you find that customers may have, you know, done suspicious transactions and they're asked to leave the bank, I mean, are you actually allowed to do this?
Or is this in contradiction with kind of your obligations, where you're not supposed to inform them if, you know, they've, they've done suspicious activity and that's then been reported? Thank you.
If I take your last question first. We can't say that we have reported them, but what we can say is that we see activity that is not in line with the procedures that we have or the standard that we have in Swedbank. And for that reason, we are absolutely allowed to do that. You are welcome as a client in Swedbank, but you need to follow our rules. The thing is also that we have a risk appetite that we apply to this. And, as you know, we are a low-risk bank, and in this area, we are zero. So we do ask customers to leave, and it's... At times it's very difficult, but we have followed through on that.
And that has been important, because it's also a very important sign to the market, that they know that if you want to be a customer of ours, you need to follow these. So that was your first question, which was on the processes. We do have a KYC process that everybody has, and then we actually update that once a year. But the thing is that... And then on the transaction monitoring, we use risk indicators. We set up a lot of different scenarios and risk indicators, and that is the way we work. And when we catch things, we go back and also look again at the KYC, what we did initially, and see if something has changed. So we are reasonably...
I think we catch when things change in customer status, et cetera.
And then with, of course, to your question about the 1,000 customers, non-resident customers, I refer you back to what Birgitte and I mentioned earlier, that we have about 1% of our total customer base in the Baltics being non-resident customers, and we have roughly 3 million customers in the Baltics. So 1,000 customers of any sort, being non-resident, is a realistic number, but we don't know what it relates to when they mention it in their program.
Okay, thank you.
Right. The next question is from the line of Bruce Hamilton at Morgan Stanley. Please go ahead. Your line is now-
Hi there, and thank you very much for taking my question. I just wanted to clarify on the comments you made earlier regarding Browder, 'cause there's some Bloomberg headlines that where he alleging that he's saying it's not true, that he's not planning a case against Swedbank. So could you just, sorry, clarify what your comments were, just to make sure I've interpreted correctly? Thank you.
Gregori here. When we talked to Bill Browder earlier today, he confirmed that he will look at this, based on the TV program today. And then, if needed, he will hand over the material to us and to relevant authorities.
Got it. Thank you.
The final question we have time for today is over the line of Richard Smith at KBW. For today's final question, Richard, please go ahead.
Bruce, Bruce has actually just asked my follow-up, so I'll pass. Thank you.
Okay, in that case, may I please pass it back to you for any closing comments at this stage?
Thank you, and thanks, everyone, for participating so actively. If there are any follow-up questions, please direct them to myself, and we'll make sure we address them as quickly as possible. Thank you, and have a good night. Bye-bye.
This now concludes today's announcement. Thank you all very much for attending. You may now disconnect your lines.