Statement of inspection in Bedre Kredit ApS (money laundering area)
On September 13, 2019, the Danish FSA was on inspection in Bedre Kredit 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, business procedures and internal controls, as well as customer knowledge procedures, including monitoring private and corporate customers.
Risk assessment and summary
The company offers consumer credits of between DKK 500 and 10,000 to private customers residing in Denmark, and does not receive cash payments.
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 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.
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 that the company may be used to finance terrorism. The company is therefore required to revise the risk assessment accordingly.
The company is instructed to revise its money laundering policy so that the policy is based on the company’s risk assessment and sets the company’s overall strategic objectives in the area of money laundering, as well as contains the basic decisions on how the company should be organized so as to counter the risks of money laundering and terrorist financing.
The company is instructed to ensure that the company collects identity information on all the company’s customers and that the company checks the customers’ identity information by a reliable and independent source.
The company is instructed to ensure that the company undertakes the necessary monitoring of established business relationships with the company’s customers, including that the information about the customer is regularly updated.
The company is instructed to carry out stricter knowledge management procedures in customer relationships where it has assessed that there is an increased risk of money laundering and terrorist financing, including, if necessary, obtaining information on the origin of the funds.
Finally, the company is being prosecuted for failing to have written business procedures to combat money laundering and terrorist financing before January 28, 2019.