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Finanstilsynet inspection of Kamath Online I/S

Statement of inspection in Kaah Online I / S (money laundering area)

In January 2018, the Danish FSA was on inspection at Kaah Online I / S (hereafter the company). The inspection was an investigation of the money laundering area as part of the ongoing supervision of the company. In particular, the inspection included the company’s risk assessment, customer knowledge procedures, investigation, listing and notification obligations.

Risk assessment and summary

Since March 11, 2015, the company has had a limited license to offer payment services in Denmark, cf. the Payment Act (money transfer business).

The company is owned by Ahmed Hassan Hirsi and Deeq Noor Kadiye with 50% each and runs money transfer business mainly targeting Somalia. All transfers are done online through a payment system run by Kaah Express, an international payment company headquartered in Dubai, but owned by Somali stakeholders.

The company is not an agent, but uses the payment system made available by Kaah Express to pay a portion of the fee paid by the company’s customers. 

The FSA considers that the company’s inherent risk of being abused for money laundering or terrorist financing is high. The Danish FSA’s assessment is based on the company’s business model combined with the fact that the company primarily transfers money to Somalia.

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 revise its internal procedures, including drafting 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 ensure that customer knowledge management procedures are followed for all corporate customers, including that the company obtains information regarding legal entities’ real owners 

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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