Report on inspection in Capitolia ApS (the laundry area)
The Danish Financial Supervisory Authority was in May 2018 an inspection of the money laundering area in Capitolia ApS. The inspection included the company’s risk assessment, policies, procedures and internal controls as well as customer knowledge procedures, including monitoring of private customers.
Risk assessment and summary
The company offers smaller consumer loans to private customers through the websites kronelån.dk and simbo.dk. The company does not offer other products and is only present in Denmark.
The Danish Financial Supervisory Authority considers that the company’s inherent risk of being abused for money laundering or terrorist financing is normally assessed in relation to the average of financial companies in Denmark. In the assessment, particular emphasis has been placed on the company offering a simple financial product and that the product is only offered to private customers resident in Denmark. Conversely, the company’s customer portfolio consists solely of distance customers.
Based on the inspection, a number of supervisory reactions have been given.
The Danish FSA concluded that the company’s risk assessment does not adequately identify and assess the inherent risk of it being misused for money laundering or terrorist financing. In particular, the company lacks the risk of being abused for the financing of terrorism. The company is therefore instructed to revise its risk assessment.
The company is instructed to prepare a money laundering policy, as the company has not prepared such a policy and thus has not set the framework for the company’s risks or the overall strategic objectives for preventing money laundering and terrorist financing for the company’s identified risks.
The company is instructed to revise its procedures so that they are based on the company and reflect the actual work procedures.
Finally, the company is instructed to ensure that the company’s money launderer approves the establishment and continuation of business relationships with politically exposed persons, their related and close business partners.