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Finanstilsynet inspection of Amal Express Travel

Amal Express Travel Inspection Statement (Money Laundering Area)

On February 13, 2018, the Danish FSA was on inspection in Amal Express Travel (hereafter the company). The inspection was an investigation of the money laundering area as part of the ongoing supervision of the company. The inspection included in particular the company’s compliance with the rules in the area of ​​money laundering, including customer knowledge, credentials, monitoring and investigative duty.

Risk assessment and summary

Since September 2, 2011, the company has had a limited license to provide payment services in Denmark, cf. the Payment Act (money transfer business).

The company operates money transfer business mainly targeting Somalia. All transfers are done online through a payment system run by Amal Express, an international payment company that has offices in Dubai and Somalia.

The company is not an agent, but has an agreement to use a payment system made available by Amal Express.

The FSA considers that the company’s inherent risk of being abused for money laundering or terrorist financing is high. The assessment places particular emphasis on the fact that money transfer companies are mentioned in Denmark’s national risk assessment in the area of ​​money laundering as a business area that involves high risk of money laundering and terrorist financing, combined with the fact that the company transfers money to Somalia primarily.

Based on the inspection, there are a number of areas that give rise to supervisory reactions. In view of the time that has passed since the inspection was carried out, the Danish FSA is aware that conditions may have changed significantly.

The company is instructed to prepare a risk assessment, as the Danish Financial Supervisory Authority finds that the company does not have one.

The company is also instructed to develop a money laundering policy that defines the risks the company wishes to take in relation to money laundering and terrorist financing, and which is based on the company’s risk assessment.

In addition, the company is required to revise its internal procedures so that they comply with applicable law, provide a sufficient description of the company’s customer knowledge procedures, and include a description of the company’s internal controls in the area of ​​money laundering. 

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


Inspection Statement

Categories: Anti-Money Laundering Finanstilsynet Updates Inspection Reports


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