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Finanstilsynet inspection of Creamfinance Denmark ApS

Statement of inspection in Creamfinance Denmark ApS (money laundering area)

On July 3, 2019, the Danish FSA was inspected by Creamfinance Denmark 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, policies, procedures and internal controls, as well as customer knowledge procedures, including customer monitoring.

Risk assessment and summary

The company is registered under section 48 (2) 1, of the Money Laundering Act, as the company carries on business lending activities.

Creamfinance Denmark ApS is a Danish company offering short-term financial solutions (loans) to individuals over 21 years in Denmark. Creamfinance Denmark ApS is established with a license to conduct lending operations in 2015 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 in the Danish market. Conversely, the company’s customers are distance customers.

Based on the inspection, there are a number of areas that give rise to supervisory reactions. The FSA found that the company’s risk assessment does not adequately contain a documented analysis of the company’s risk factors and does not adequately address the risk of the company being abused for money laundering and terrorist financing.

Against this background, the company is instructed that the risk assessment must be revised accordingly.

The company is also required to revise the company’s money laundering policy so that it is based on the company’s risk assessment and clearly identifies and delineates what risks the company wishes to take in relation to money laundering and terrorist financing.

The company is instructed to ensure that the company checks the customers’ identity information by a reliable and independent source.

The company is also instructed to ensure that the company conducts the necessary monitoring of its customers.

The company is instructed to ensure that the company continuously updates the company’s information and data about its customers.

The company is also instructed to ensure that stricter customer knowledge procedures are conducted in customer relationships, where the company has assessed that there is an increased risk of money laundering and terrorist financing.

The company is instructed to ensure that internal checks are carried out on whether the company complies with the requirements of the Money Laundering Act and that the checks made are 
documented.

The company is instructed to ensure that the continuation of a business relationship with a customer who is granted a politically exposed person and customer relationship with a close or close business partner of a politically exposed person is approved by the money laundering officer.

Finally, the company is instructed to ensure that its employees, including management, receive adequate training in the requirements of the Money Laundering Act.

The company is being sued for not having had a whistleblower scheme until the company entered into a whistleblower scheme with a company on July 1, 2019. 
The Danish Financial Supervisory Authority has notified the company of violations of the rules in the Money Laundering Act on knowledgeable procedures, sharpened knowledgeable procedures and ongoing monitoring of customers.

Link:

Inspection Report

Categories: Anti-Money Laundering Finanstilsynet Updates Inspection Reports

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