The inspection was a study of the money laundering area as part of the ongoing supervision of the branch. The inspection included the branch’s procedures and internal controls as well as customer knowledge procedures, including monitoring of private customers and business customers.
Risk assessment and summary
SEB Kort Bank AB is a 100% owned subsidiary of SEB AB, which is domiciled in Sweden. SEB Kort Bank AB has established a Danish branch, which offers payment and credit cards to private customers and business customers.
The Danish Financial Supervisory Authority considers that the inherent risk of the branch being abused for money laundering or terrorist financing is normal to high in relation to the average of financial companies in Denmark. In the assessment, special emphasis has been placed on the fact that the branch’s offered products can be used for money transfers, and that the branch’s customer portfolio consists solely of distance customers.
Based on the inspection, there are a number of areas that give rise to supervisory reactions.
The branch is ordered to ensure that its stricter customer knowledge procedures entail that the branch obtains additional information about customers that the branch considers to be associated with a high risk of money laundering or terrorist financing.
The branch is instructed that it should assess when it is relevant to identify the purpose and purpose of a business relationship, since the Danish FSA concluded that the branch does not make a concrete assessment of this.
The branch is ordered to ensure that the transaction monitoring is adapted to the branch’s knowledge of the individual customer, including the customer’s risk profile and expected business volume.
Finally, the branch is ordered to ensure that sufficient controls are carried out in the operating units as to whether the branch complies with the requirements of the Money Laundering Act. The order is based on the fact that the branch’s internal controls are primarily performed by compliance and internal audit.