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 passengers (private customers) and to ship crew (employees).
The company offers currency exchange operations in Denmark from the two vessels “Crown Seaways” and “Pearl Seaways”, sailing on the route between Copenhagen and Oslo. The company receives both cash and card payments. The company’s private customers consist mainly of tourists who exchange for holiday purposes in connection with their stay on the ships.
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. In the assessment, the FSA has placed particular emphasis on the fact that currency exchange operations are generally considered to have a high inherent risk of being exploited for money laundering or terrorist financing.
Conversely, the assessment also emphasizes that the currency exchange business is exercised under special conditions, including the additional security measures as a result of the business being carried on board a ship. Among other things, this includes that all customers must buy a ticket and legitimize themselves before boarding the ships, and that DFDS must deliver passenger lists to customs and police authorities under other legislation.
Based on the inspection, there are some areas that give rise to supervisory reactions.
The company is instructed to ensure that the company retains identity and verification information and a copy of the credentials presented for currency exchange on the ship “Pearl Seaways”.
The company is required to have procedures to determine whether customers are politically exposed persons (PEP) or close or close partners of a politically exposed person.
The company is instructed to ensure that its customers are not listed in EU regulations containing financial penalties.
Finally, the company is being prosecuted for failing to keep proven credentials from exchanges on the ships before March 2018.