Risk assessment and summary
Sparekassen Kronjylland is a medium-sized financial institution whose primary market area is East and Central Jutland. Sparekassen focuses on private customers as well as small and medium-sized business customers.
The Danish Financial Supervisory Authority considers that the Savings Bank’s inherent risk of being abused for money laundering or terrorist financing is normal to high compared to the average of financial companies in Denmark. The assessment places particular emphasis on the fact that the Savings Bank has a number of foreign correspondent relations outside the EU / EEA.
The Savings Bank was instructed to ensure that the money laundering policy limits the savings bank’s risks in the area of money laundering and to ensure that the policy is arranged in such a way that it can form the basis for a reporting.
In addition, the Savings Bank was instructed to ensure that, in connection with the establishment of a correspondent relationship outside the EU / EEA, the Savings Bank assesses the information obtained as part of the customer knowledge procedure. The assessment must clarify the risk elements associated with the establishment of the specific correspondent connection. In cases where the Savings Bank considers that stricter requirements for the knowledge of the procedure for establishing a correspondent relationship within the EU / EEA apply, the
Savings Bank shall also assess the information obtained and clarify the risk elements associated with the establishment.
Sparekassen was also instructed to ensure that the business processes on correspondent relations are expanded to specify which elements should be included in the assessment of the customer knowledge material obtained prior to the establishment and in the ongoing monitoring.
In addition, the Savings Bank was instructed to draw up adequate procedures for the implementation of internal controls in the area of money laundering.
Finally, the Savings Bank was charged that the Savings Bank’s internal audit had not carried out an audit of risk management in the area of money laundering and terrorist financing. However, the Financial Supervisory Authority found during the inspection that the internal audit had planned a review of the money laundering and terrorist financing area during 2018.