Statement on inspection in Global Exchange Denmark ApS (money laundering area)
In September 2020, the Danish Financial Supervisory Authority inspected Global Exchange 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 has a permit for currency exchange pursuant to section 41 of the Money Laundering Act. The company is part of the Spanish group Global Exchange Group, which in addition to Denmark is established in 22 countries on 5 continents.
The company only offers currency exchange and has three exchange offices at Billund Airport and seven at Copenhagen Airport. The company’s customers typically consist of traveling physical customers, including tourists and business travelers, and the company receives both cash and card payments. The company’s customers also have the opportunity to exchange relatively large amounts.
The Danish Financial Supervisory Authority assesses that the company’s inherent risk of being used for money laundering or terrorist financing is highly assessed in relation to the average of financial companies in Denmark. The Danish FSA’s assessment is based on the assessment of the inherent risk associated with currency exchange business in general, the company’s location at the airport, where customers often travel out of the country after the currency exchange transaction, and that large amounts may be involved.
Based on the inspection, a number of areas have given rise to supervisory reactions.
The company is instructed to revise its risk assessment so that it is based on the company’s business model, and which on that basis includes an assessment of the risk factors associated with the company’s customers, products, services and transactions as well as delivery channels and countries or geographical areas. In addition, the company must ensure that the risk assessment covers the company’s risk separately for money laundering and terrorist financing, and that the risk assessment is substantiated with relevant data and is also based on the national and supranational risk assessments.
The company is instructed to ensure that the policy in the area of money laundering is based on the company’s risk assessment and sets the 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.
The company is also instructed to prepare written business procedures for stricter customer knowledge procedures.
The company is ordered to ensure that the money launderer approves the company’s policies, controls and business procedures.
Finally, the company is ordered to ensure that the company includes Annexes 2 and 3 of the Money Laundering Act in the risk classification of customers.