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Danish FSA inspects Nelleman Leasing A/S

Statement of inspection in Nellemann Leasing A / S (money laundering area)

In April 2019, the Danish FSA was on inspection at Nellemann Leasing A / S. The inspection was an investigation of the money laundering area as part of the ongoing supervision of the company. The inspection included the company’s risk assessment, policies, procedures and internal controls, as well as customer knowledge procedures, including customer monitoring.

Risk assessment and summary

The company is registered under section 48 (2). 1, of the Money Laundering Act, as the company provides financial leasing for business. 

The company offers various financial leasing products to private and corporate customers, including flex leasing, private leasing, business leasing, split leasing and seasonal leasing. The company is part of the Nellemann Group. The company only serves customers residing in Denmark and does not receive cash payments.  


The Danish Financial Supervisory Authority considers that the company’s inherent risk of being abused for money laundering or terrorist financing is normal to high assessed in relation to the average of financial companies in Denmark. The assessment places particular emphasis on the fact that leasing companies are generally considered to have an increased inherent risk of being used for terrorist financing. Conversely, the company does not accept cash payments, just as the company’s customers primarily consist of customers residing in Denmark, who are physically present with the company when establishing the customer relationship.


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


The company is ordered to carry out internal checks on whether the company complies with the requirements of the Money Laundering Act.


The company is being sued for not formally appointing a money laundering officer before April 2019. 


Finally, the company is being sued for failing to investigate whether its customers are listed in EU financial penalties regulations before March 2019.


Finanstilsynet notice

Categories: Anti-Money Laundering Finanstilsynet Updates Inspection Reports


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