Statement on inspection in eCommerce 2020 ApS (money laundering area)
On July 8, 2019, the Danish FSA was inspected in eCommerce 2020 ApS.
Risk assessment and summary
eCommerce is a Danish company offering short-term financial solutions (loans) to individuals over the age of 18 in Iceland. eCommerce 2020 ApS was established in 2016 with license from June 2017 and is headquartered in Denmark.
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 Danish FSA has placed particular emphasis on the fact that the company offers a single financial product and that the product is only offered to private customers. Conversely, the company’s customers are distance customers.
The FSA found that the company’s risk assessment does not adequately identify and assess the inherent risk that the company may be used for money laundering or terrorist financing. In particular, the company has to deal separately with the risk that it may be used to finance terrorism. The company is therefore required to revise its risk assessment accordingly.
The company is also required to revise its money laundering policy so that it clearly identifies and delineates the risks it intends to take in the area of money laundering and the overall strategic objectives for money laundering and terrorist financing for its identified risks.
The company is also required to prepare written procedures for how the company will carry out internal controls with appropriate frequency, ensuring that it effectively prevents, mitigates and manages the risk of money laundering and terrorist financing, and that it can document the checks made.
The company is also required to carry out adequate customer knowledge procedures for all customers, and this can be reimbursed to the Danish Financial Supervisory Authority.
The company is instructed to monitor its customer relationships in order to assess whether the customer’s transactions are in accordance with the company’s knowledge of the customers and the assessment of the customer’s risk.
Finally, the company is instructed to investigate the background and purpose of all complex and unusual transactions and activities in order to determine whether there is any suspicion or reasonable reason to suspect that they are or have been associated with money laundering or financing of terrorism.
The Danish Financial Supervisory Authority has notified the company of violations of the rules in the Money Laundering Act on customer knowledge procedures, stricter customer knowledge procedures and ongoing monitoring of customers.