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Finanstilsynet inspection of 4Finance ApS

Statement of inspection in 4Finance ApS (money laundering area)

On April 25, 2018, the Danish FSA was inspected at 4Finance ApS. 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, written policies, procedures and internal controls, as well as the company’s customer knowledge, including customer monitoring.

Risk assessment and summary 

The company offers smaller consumer loans to private customers via the Internet through the company’s brands and The company does not offer other products and is only present in the Danish market. 

The Danish FSA assesses that the company’s inherent risk of being used for money laundering or terrorist financing is normally assessed in relation to the average of financial companies in Denmark. In the assessment, the Financial Supervisory Authority placed particular emphasis on the fact that the company offers a single financial product and that the product is only offered to private customers residing in Denmark. Conversely, the company’s customer portfolio consists exclusively of distance customers.

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 Danish Financial Supervisory Authority found that the company does not adequately identify and assess the inherent risk of the company being used for money laundering or terrorist financing. This is especially true of the risk of the company being used to finance terrorism. The company is therefore required to revise its risk assessment.

The company is given an injunction to develop a money laundering policy, as the company has not prepared one and thus has not set the overall strategic objectives in relation to the prevention of money laundering and terrorist financing and the risks the company wishes to take.

Finally, the company is required to ensure that, before establishing a business relationship, the company carries out stricter customer knowledge procedures, in cases where the company considers this to be relevant.


Inspection Report

Categories: Anti-Money Laundering Finanstilsynet Updates Inspection Reports


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