Statement on inspection in Secure Fondsmæglerselskab A / S (money laundering area)
In February 2020, the Danish Financial Supervisory Authority inspected Secure Fondsmæglerselskab A / S.
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 compliance with the Money Laundering Act’s rules on customer knowledge procedures as well as the duty to investigate and notify.
Risk assessment and summary
Secure Fondsmæglerselskab is a stockbroking company that offers wealth management and long-term investments for its clients. The company was founded in March 2008 and is headquartered in Kgs. Lyngby.
The Danish Financial Supervisory Authority assesses that the company’s inherent risk of being used for money laundering or terrorist financing is low to normal compared to the average of financial companies in Denmark. In the assessment, the Danish Financial Supervisory Authority has placed special emphasis on the fact that there is a narrow national customer base with a view to long-term investments, just as the company does not store customer funds. Whether it is discretionary portfolio management or alternative investments, all transactions take place via the customers’ bank, either in the form of a trading instruction or by the customer making the transfer to the alternative investment fund in question.
Based on the inspection, a number of areas have given rise to supervisory reactions.
The company is ordered to prepare a risk assessment that deals separately with the risk of money laundering and terrorist financing, respectively. The risk assessment must be based on the company’s business model and on the basis of this include an assessment of the risk factors associated with the company’s customers, products and transactions.
The company is also instructed to ensure that the money laundering policy is based on the company’s risk assessment, sets the overall strategic goals in the money laundering area, and contains the principled decisions on how the company should be organized so that the risks of money laundering and terrorist financing are met.
The company is also instructed to ensure that the company, in connection with the establishment of business relationships, makes a specific risk classification of its customers, based on the customers’ actual circumstances.
The company is instructed to prepare business procedures for how the company should handle customers with an increased risk, and that the company conducts stricter customer knowledge procedures in the customer relationships where it is assessed that there is an increased risk of money laundering and terrorist financing, including if necessary obtain information on the origin of the funds.
The company is also instructed to ensure that the company carries out the necessary monitoring of its customers, including that documents, data and information about the customers are continuously updated, and that the company keeps the documentation in question.
The company is instructed to ensure that the company has procedures to determine whether customers in an ongoing customer relationship become politically exposed persons or close or close partners of a politically exposed person.
The company is also instructed to ensure that the company carries out the necessary monitoring of the company’s customers, including politically exposed persons, in order to assess whether the customers’ transactions are in accordance with the company’s knowledge of the customers, including that the customer information is continuously updated.
The company is also instructed to ensure that the company investigates suspicious transactions, including that the results of these investigations are noted and stored, and that this can be proven to the Danish Financial Supervisory Authority.
The company is finally ordered to prepare business procedures for notifications to the Money Laundering Secretariat, which must ensure that the company immediately notifies the Money Laundering Secretariat by identifying suspicions of money laundering or terrorist financing.