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Finanstilsynet Inspection Report: Kreditbanken

Statement on inspection at Kreditbanken (money laundering area)

In January 2020, the Danish Financial Supervisory Authority inspected Kreditbanken A / S. The inspection was an investigation of the money laundering area as part of the ongoing supervision of the bank. The inspection included the bank’s policies, procedures and internal controls. In addition, the inspection included customer due diligence procedures, monitoring of private and corporate customers as well as the bank’s listing, investigation and notification obligations.

Kreditbanken A / S is a locally based bank whose primary market area is Southern Jutland. The bank has a traditional business model with ordinary deposit and lending products, including uncomplicated financial products in the banking, mortgage, investment, pension and insurance areas.

The bank has a collaboration with Nord-Ostsee Sparkasse (NOSPA) in Germany on a customer group living in Germany with earned income from Denmark. The collaboration is based on the fact that NOSPA cannot receive payments to German accounts from Danish employers. The bank is therefore included as an intermediary in the cash flows from the Danish employers to German resident employees in the companies.

The Danish FSA assesses that the bank’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 bank offering a number of different financial products to both private customers and business customers. Conversely, the bank limits its business to traditional financial products and is primarily based in its local area with customers who primarily reside in Denmark, with the exception of NOSPA customers.

Based on the inspection, there are a number of areas that give rise to supervisory reactions.

On the basis of the cross-cutting off-site inspection regarding the risk assessment in the money laundering area, which the Danish Financial Supervisory Authority carried out in a number of banks in November-December 2019, the bank was ordered to revise its risk assessment. In connection with this, the bank will be instructed to revise its money laundering policy so that it is based on the bank’s risk assessment and contains an identification and delimitation of how the bank will respond to the risks in the money laundering area.

The bank is instructed to prepare adequate business procedures regarding monitoring of customer relationships as well as compliance with the investigation, listing and notification obligation.

The bank is also instructed to ensure that it obtains sufficient customer knowledge information regarding customers covered by the agreement with NOSPA.

In addition, the bank is instructed to ensure that it conducts adequate investigations of alarms from the bank’s monitoring, including that the bank notes and documents the results of these investigations.

The bank is ordered to ensure that it notifies the Money Laundering Secretariat immediately by identifying any suspicion or when the bank has reasonable grounds to believe that a transaction, means or activity has or has been linked to money laundering or terrorist financing. .


Inspection Report

Categories: Anti-Money Laundering Finanstilsynet Updates Inspection Reports


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