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Finanstilsynet Inspection Report: Leasing Fyn Bank A/S

Statement on inspection in Leasing Fyn Bank A / S (money laundering area)

In April 2020, the Danish Financial Supervisory Authority inspected Leasing Fyn Bank. 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 due diligence procedures, including monitoring of private and corporate customers.

Risk assessment and summary

Leasing Fyn Bank A / S functions as a management company jointly owned by the three leasing companies; Leasing Fyn Faaborg A / S, Leasing Fyn Middelfart A / S and Leasing Fyn Svendborg A / S.   These three leasing companies are owned by three banks, Sparekassen Sjælland-Fyn A / S, Middelfart Sparekasse A / S and Fynske Bank A / S, respectively.

The company’s business model is based on selling leasing and factoring solutions, with a special focus on transport, industrial and agricultural companies. The company’s customer segment consists primarily of corporate customers in Denmark, as the company has a special focus on small and medium-sized companies.

The Danish Financial Supervisory Authority assesses that the company’s inherent risk of being misused for money laundering or terrorist financing is normal to high assessed in relation to the average of financial companies in Denmark. In the assessment, special emphasis is placed on the fact that leasing activities are generally considered to have an increased risk of being used for terrorist financing [1] . The company limits its banking activity to deposits and factoring products, and is primarily based in its local area with customers who live in Denmark. The company does not offer its bank customers online banking, which is why all transactions must take place via contact with the company.

On the basis of the inspection, a number of areas have given rise to supervisory reactions.

The company is instructed to revise the company’s risk assessment so that it adequately identifies and assesses the risk of the company being used for money laundering and terrorist financing. In doing so, the company must ensure that the risk assessment uncovers the company’s risk separately for money laundering and terrorist financing.

In addition, the company is instructed to ensure that the money laundering policy is based on the company’s risk assessment, sets the company’s overall strategic goals in the area of ​​money laundering, and contains the principled decisions on how the company should be organized so that the risks of money laundering and terrorist financing are met.

Finally, the company is instructed to expand its business processes so that they include a business process for screening employees.

The company must also revise its business procedures for the implementation of customer due diligence procedures and for compliance with the investigation, listing and notification obligation, so that the business procedures are operational and thus clearly state how the company’s employees are to perform their tasks.  


Inspection Report

Categories: Anti-Money Laundering Finanstilsynet Updates Inspection Reports


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