Finanstilsynet Inspection Report: Interdan Leasing A/S
Statement on inspection in Interdan Leasing A / S (money laundering area)
In February 2020, the Danish Financial Supervisory Authority inspected Interdan Leasing A / S.
The inspection was an investigation of the money laundering area. The inspection included the company’s risk assessment, policies, procedures and internal controls. In addition, the inspection included customer due diligence procedures, monitoring of private and business customers as well as the company’s investigation, listing, notification and storage obligations.
Risk assessment and summary
The company runs a leasing business and offers i.a. flexleasing and sale and lease back. The company refers customers who want a split leasing agreement to Dansk Splitleasing, and the company has stated that sale and lease back takes place extremely rarely, which is why the company’s primary business is based on flex leasing. The company offers leasing of cars to private as well as business customers.
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, the Danish Financial Supervisory Authority has placed special emphasis on the fact that leasing companies are generally considered to have an increased inherent risk of being used for terrorist financing. Conversely, the company’s customers primarily consist of customers resident in Denmark who are physically present with the company when establishing the customer relationship, and the company does not receive cash payments.
Based on the inspection, there are several areas that give rise to supervisory reactions.
The company is instructed that the company’s risk assessment must be revised so that it adequately contains a documented analysis of the company’s risk factors and addresses the risk that the company may be used for money laundering and terrorist financing.
The company is also instructed to revise its money laundering policy so that it clearly includes an identification and delimitation of the risks that the company’s business model entails, the principles for risk management and the risk areas within which the company operates. The policy must reflect the company’s specific risk profile, including the company’s business model and the company’s risk assessment.
The company is ordered to ensure that the company’s customers’ identity information is checked on the basis of documents, data or information that the company has obtained from a reliable and independent source, and that this can be proven to the Danish Financial Supervisory Authority. Below, the company must obtain information about the real owners of legal clients.
The company is ordered to ensure that the company can prove to the Danish Financial Supervisory Authority that the company’s knowledge of its customers is sufficient in relation to the risk of money laundering and terrorist financing.
The company is also instructed to ensure that the company continuously updates the company’s information and data regarding all its customers.
The company is also instructed to ensure that it conducts stricter customer due diligence procedures in customer relationships where the company has assessed that there is an increased risk of money laundering or terrorist financing.
The company is also instructed to ensure that the company carries out the necessary monitoring of the company’s customers in order to ensure that the customers’ behavior and activities are in accordance with the company’s knowledge of the customers.
The company is instructed to revise the company’s business procedures regarding inspection, listing, notification and storage obligations.
The company is instructed to ensure that the company examines unusual transaction patterns and activities of its customers and notes and stores the results of the investigations, and that the company can document this.
The company is ordered to ensure that an internal check is made of whether the company complies with the requirements of the Money Laundering Act, and the company can document the checks carried out.
The company is ordered to ensure that the company has business procedures to determine whether the company’s customers are a politically exposed person or a close or close partner of a politically exposed person.
The company is also instructed to ensure that the company has procedures to determine whether customers in an ongoing customer relationship become a politically exposed person or a close or close partner of a politically exposed person, and that the continuation of business relationships with such a customer is approved by the money launderer.
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