Finanstilsynet inspection: Dan Exchange A/S
Statement of inspection in Dan Exchange A / S (money laundering area)
In February 2018, the Danish FSA was inspected at Dan Exchange A / S. The inspection was an investigation into the money laundering area as part of ongoing supervision of the company as an agent of Western Union Payment Services Ireland Limited (WUPSIL).
The inspection included the company’s knowledge of the risk assessment prepared by WUPSIL, the company’s knowledge of and implementation of the written policies, procedures and internal controls prepared by WUPSIL, the company’s performance of customer knowledge, including the physical monitoring of customers and training of the company’s employees in the rules in the money laundering area.
Risk assessment and summary
The company conducts money transfer business as an agent for WUPSIL . In addition, the company has a limited license to conduct money transfer business in Denmark as well as a license to offer currency exchange. The inspection only concerned the money transfer company as an agent for WUPSIL.
The Danish Financial Supervisory Authority considers that the company’s inherent risk of being abused for money laundering or terrorist financing as an agent for a money transfer company is highly rated in relation to the average of financial companies in Denmark. In the assessment, the Danish FSA has placed particular emphasis on the fact that money transfer companies are generally considered to have a high inherent risk of being exploited for money laundering or terrorist financing.
Based on the inspection, there are no areas that give rise to supervisory reactions in relation to the company.
However, the Danish FSA considers it appropriate to make a number of recommendations to WUPSIL regarding matters for which WUPSIL was responsible in relation to the company, including:
that WUPSIL’s written procedures and training programs for agents in Denmark were not updated to reflect the applicable money laundering law,
that the thresholds used in WUPSIL’s customer software did not ensure that information on the origin of the funds in relation to customer transactions was not always obtained where relevant, and
that WUPSIL’s systems did not support WUPSIL’s agents obtaining and storing copies of credentials during the period from June 2017 to February 2018.
Categories: Anti-Money Laundering Finanstilsynet Updates Inspection Reports