Finanstilsynet Inspection Report: Digital Easy ApS
Statement on inspection in Digital Easy ApS (money laundering area)
In April 2020, the Danish Financial Supervisory Authority inspected Digital Easy ApS. The inspection was an investigation of the money laundering area. The inspection included the company’s policies, procedures and internal controls as well as customer due diligence procedures including monitoring of customers.
Risk assessment and summary
The company offers exchange between Bitcoin and Danish kroner to both private and corporate customers. The company is located at Copenhagen Airport and only offers its customers exchange service from the company’s business premises.
The Danish Financial Supervisory Authority assesses that the company’s inherent risk of being used for money laundering or terrorist financing is normal to high in relation to the average of financial companies in Denmark. In the assessment, the Danish Financial Supervisory Authority has placed special emphasis on the company receiving cash in connection with the exchange benefit. However, the company’s business model is simple, as there is only an exchange between Bitcoin and Danish kroner, and the company also does not have distance customers. It is also included in the Danish FSA’s assessment that each exchange is documented on Bitcoin’s blockchain, which is publicly available.
Based on the inspection, three areas have given rise to supervisory reactions.
The company is instructed to revise the company’s risk assessment so that it identifies and assesses the risk that the company will be used for money laundering and terrorist financing.
The company is instructed to ensure that the company’s policy in the area of money laundering 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 revise a number of business procedures so that they specify the specific activities that the employees must perform.
Categories: Anti-Money Laundering Finanstilsynet Updates Inspection Reports