Danish inspection report: Unitravel / Hasle Exchange v / Muna Al-Mansouri

Statement on inspection in Unitravel / Hasle Exchange v / Muna Al-Mansouri (money laundering area)

In March 2019, the FSA was on inspection in Unitravel / Hasle Exchange v / Muna Al-Mansouri. The inspection was an investigation of the money laundering area as part of the ongoing supervision of the company. The inspection included compliance with the rules of customer knowledge, monitoring, investigation, notification and listing.

Risk assessment and summary

The company is authorized to exchange currency pursuant to section 41 of the Money Laundering Act.

The company offers currency exchange to private and corporate customers. In addition, the company is a money transfer agent for MoneyGram International Limited.

The company only receives cash, since the company does not have a bank account. The company’s business model, for the part of the company that deals with currency exchange, consists mainly of currency exchange for private customers. The company’s private customers primarily consist of permanent premises, which switch to, for example, holiday purposes, as well as foreign students.

The FSA considers that the company’s inherent risk of being abused for money laundering or terrorist financing is highly rated in relation to the average of financial companies in Denmark. The Financial Supervisory Authority’s assessment is based on the fact that the company receives cash only, as well as the assessment of the inherent risk of money laundering and terrorist financing associated with currency exchange operations.

Based on the inspection, there are some areas that give rise to supervisory reactions.

The company is instructed to ensure that legal persons obtain information on the CVR number and real owners, that reasonable measures are taken to clarify the legal person’s ownership and control structure, and that this can be reimbursed to the Danish Financial Supervisory Authority. 

Finally, the company is instructed to ensure that investigations of unusual transactions are noted and documented.

Link:

Inspection Report

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