Sami Lommi

Counsel, Compliance Officer, Head of Risk Management, Member of the Finnish Bar

Services

  1. Capital Markets & Public M&A
  2. Financial Regulation
  3. Compliance & Risk
  4. Corporate Governance
  5. Insurance

Contact details

I am the head of our Insurance service and specialise in financial and insurance regulation as well as anti-money laundering and sanctions regulation. I advise domestic and foreign financial institutions, insurance companies and significant owners in a variety of regulatory matters, such as transactions and investigations. I also extensively advise clients in AML/CTF/KYC related matters, supporting them in acting in compliance with applicable regulation. I am Castrén & Snellman’s compliance officer and head of the company’s Risk Management service.

For over a decade prior to joining Castrén & Snellman I held several positions in the insurance sector, most recently as the director of legal affairs, HR and internal services in the management team of a non-life insurance company. During my career, I have also gained experience as a compliance officer both in a domestic banking concern and an international insurance concern. As I have also held numerous positions of trust within the insurance sector, I have had the opportunity to actively participate in influencing the development of the regulatory framework.

As the amount of financial and insurance regulatory work has expanded in recent years, becoming more complicated with swelling regulations coming mostly from the EU, my versatile background as an in-house counsel provides invaluable insight and experience of insurance corporate practice and the insurance sector in general. Having worked as an in-house counsel, I strive to take identified business challenges into consideration when applying the legal framework. I like to think of myself as an enabler.

Latest references

International reinsurance companies – Ad hoc arbitration proceedings
We successfully represented a panel of reinsurance companies in an international ad hoc arbitration. The dispute arose out of a reinsurance treaty under the terms of which the reinsurers had reinsured a portfolio of risks underwritten by the cedent. The parties disagreed as to whether the reinsurance provided coverage for a certain loss that had occurred because of the market turmoil caused by the Covid-19 pandemic. The case involved highly complex legal and contractual questions requiring special expertise on reinsurance law and practice. The arbitral tribunal rejected the counterparty’s claims for reinsurance compensation against our clients in full. The amount in dispute was approximately EUR 34 million.
Case published 16.9.2025
Merger of Oomi and Lumme Energia
We are acting as the joint legal advisor to Oomi Oy and Lumme Energia Oy in a transaction whereby Lumme Energia will merge with Oomi. As from the completion of the merger, the combined entity will be the largest electricity retail and service company in the Finnish market. In 2024, Oomi reported a turnover of EUR 373.9 million and had approximately 110 employees. Lumme Energia’s turnover for the same year was approximately EUR 314.6 million and it had approximately 50 employees. The transaction is primarily driven by the recent developments in the electricity market and the strategic goal to develop competitive products and services. Another key objective is to further enhance the customer experience, which is a shared value between the two companies. As a result of the merger, Lumme Energia’s customers will transfer to Oomi, and Lumme Energia will become one of Oomi’s shareholders. The completion of the transaction is subject to an approval by the Finnish Competition and Consumer Authority.
Case published 29.8.2025
C&S Insurance Service – Castrén & Snellman’s full-service offering covers all areas of business law for the insurance sector
Castrén & Snellman is the trusted partner for companies in the insurance sector both in Finland and internationally. We have assisted our clients in matters such as obtaining authorisation for activities transactions, such as insurance portfolio transfers and ownership control processes system acquisitions disputes outsourcing arrangements sales, marketing and insurance distribution matters. We have extensive experience in the insurance sector and decades of collaboration with supervisory authorities. We offer our clients our internationally recognised competence, clear thinking and solution-oriented experts.
Case published 5.12.2023
Finnish Mutual Patient Insurance Company – Procurement of an Insurance Platform
We assisted Finnish Mutual Patient Insurance Company (FMPIC) in its procurement of a SaaS-based insurance platform. The procurement was conducted as a negotiation procedure with Swedish iFACTS Ab selected as the supplier of the platform. The new platform is expected to be launched already in autumn 2022. With the procurement of the insurance platform, FMPIC aims for better and more reliable management and processing of customer relations and insurance policies. The goal is to reduce the risks associated with managing customer relations and policies, to improve the data security and data protection of customer and insurance information and to meet regulatory requirements. FMPIC was assisted in the procurement and contract negotiations by our public procurement experts Johanna Lähde and Atte Andersin, Pia Ek and Miika Junttila from the data and technology team and by our insurance expert, Sami Lommi. 
Case published 31.5.2022
Finnish P&C Insurance – Design of Insurance Terms
We carried out a legal design project in which we designed insurance terms for Finnish P&C Insurance Ltd according to the client’s wishes. Legal design is all about multi-professional dialogue and cooperation. In this project, our team included experts in legal technology, the Finnish language, graphic design and the law. In line with the principles of legal design, the process was agile and iterative. In the first phase of the project, we delivered a prototype for commentary. The comments we received from the client enabled us to better address the client’s goals. The visual appearance of the final product was based on the client’s wishes and graphical guidelines. We kept the end-user in mind when designing the insurance terms – after all, user-centricity, or taking the target group’s needs into account, is one of the main principles of legal design. In addition to a legal review of the insurance terms, the goals for this design project included clarifying the terms and cutting down on legalese. During the project, the client’s initial draft was completely transformed. The end result was insurance terms in a compact, practical and clear format. Finnish P&C Insurance Ltd is a modern Finnish non-life insurance company that provides customised insurance services for the brands POP Insurance and Savings Bank Insurance. The digital aspect of the company was key from its foundation in 2012. The company currently has over 170,000 customers and more than 100 employees. Finnish P&C Insurance Ltd is owned by the financially sound POP Bank Group.
Case published 31.5.2022
Gjensidige Forsikring – Acquisition of Falck Räddningskår
We acted as the Finnish local counsel when Gjensidige Forsikring ASA acquired 100% of the shares in Falck Räddningskår AB, including subsidiaries in Norway, Finland, Estonia and Lithuania (Falck RSA Nordic & Baltics) from Falck Investment Sverige AB (a subsidiary under Falck A/S), for SEK 1.4 billion. Falck RSA Nordic & Baltics is a leading roadside assistance provider with nationwide franchise networks in Sweden, Norway, Finland, Estonia and Lithuania. The acquisition is in line with Gjensidige’s strategy to take a holistic approach to solving the customers’ needs and complements Gjensidige’s products and services in the Nordic mobility space. The group has 260 employees and recorded EUR 75.8 million in revenues and EUR 6 million in EBITA in 2020.
Case published 20.12.2021
Aktia Life Insurance – Inaugural Tier 2 Transaction
We assisted Aktia Life Insurance Ltd and the sole lead and Structural Advisor Danske Bank A/S in Aktia Life Insurance’s inaugural Tier 2 transaction. The purpose of the Transaction is to further support the capital structure and solvency ratio of Aktia Life Insurance. Aktia Life Insurance is an unrated entity. The unrated and unlisted Tier 2 instrument required high number of investors to be canvassed.   The final size of the transaction was EUR 56 million. Aktia Life Insurance is a wholly owned subsidiary of Aktia Bank Plc. Aktia  is a Finnish asset manager, bank and life insurer that has been creating wealth and wellbeing from one generation to the next for 200 years. We serve our customers in digital channels everywhere and face-to-face in our offices in the Helsinki, Turku, Tampere, Vaasa and Oulu regions. Our award-winning asset management business sells investment funds internationally. We employ approximately 900 people around Finland. Aktia’s assets under management (AuM) on 30 June 2021 amounted to EUR 15.6 billion, and the balance sheet total was EUR 11.2 billion. Aktia’s shares are listed on Nasdaq Helsinki Ltd (AKTIA).
Case published 14.12.2021
Ålandsbanken & Borgo – Issue of Covered Bond and Consent Solicitation for Ålandsbanken’s Covered Bond
We advised Ålandsbanken Abp and Borgo AB in respect of Finnish law in the issue of a SEK 5,500,000,000 covered bond by Ålandsbanken Abp as initial issuer and Borgo AB as subsequent issuer.  The terms and conditions of the covered bonds allow covered bonds to be transferred to Borgo AB at a later stage subject to the approval of Ålandsbanken Abp and Borgo AB. The contemplated timing for the transfer s the first half of 2022. The new covered bond issue is part of a transaction in which Ålandsbanken Abp, ICA Banken AB, Ikano Bank AB (publ), and Söderberg & Partners Holding AB have established a new mortgage company, Borgo AB, and are further establishing a joint mortgage platform on the Swedish market. As part of this transaction, Ålandsbanken Abp will transfer its Swedish mortgage loans, SEK-denominated covered bonds it has issued, and SEK-denominated bonds from its liquidity portfolio to Borgo AB. Borgo AB is a digital start-up mortgage company licenced by the Swedish Financial Supervisory Authority. In addition to the above, we advised Ålandsbanken Abp in a consent solicitation for its up to SEK 2,500,000,000 covered bond due in 2022 and its later redemption of all outstanding notes pursuant to the amendments made to the terms and conditions of the covered bond during the consent solicitation process.
Case published 13.9.2021
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