Statement on inspection in A / S Global Risk Management (money laundering area)
In March 2020, the Danish Financial Supervisory Authority inspected A / S Global Risk Management. The inspection was an investigation of the money laundering area. The inspection included the company’s risk assessment, policies, procedures and internal controls in the area of money laundering. In addition, the inspection included customer due diligence procedures, monitoring of customers as well as the company’s inspection, listing, notification and storage obligations.
Global Risk Management is a stockbroking company that operates globally within hedging the prices of oil, fuel and energy. The company’s customers include of airlines and bunker and shipping companies that use Global Risk Management to hedge oil and fuel prices, thereby reducing customer exposure to fluctuating energy prices.
The Danish Financial Supervisory Authority assesses that the company’s inherent risk of being used for money laundering or terrorist financing is low to normal compared to the average of financial companies in Denmark. In the assessment, the Danish Financial Supervisory Authority has placed special emphasis on the fact that stockbroking companies generally involve a limited risk, but that a large proportion of the company’s customers are also established outside Denmark.
Following the inspection, a number of areas have given rise to supervisory responses.
The company is instructed to revise its risk assessment so that it deals separately with the risk of money laundering and terrorist financing, respectively, and 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 supply channels and countries or geographical areas in which the business activities are carried out.
The company is ordered to ensure that the policy in the money laundering area is based on the company’s risk assessment prepared in accordance with the Money Laundering Act, section 7, subsection. 1, and sets the overall strategic goals in the field of money laundering and contains the principal decisions on how the company should be set up so that the risks of money laundering and terrorist financing are met.
The company is ordered to prepare a sufficient business procedure, which ensures that the company makes a concrete risk assessment of the individual customer relationship on the basis of the customer’s actual circumstances, so that the company can carry out a correct customer knowledge procedure, cf. section 11, subsection. 1 and 2 and § 17, para. 1.
The company is instructed to ensure that it prepares written business procedures for how the company implements stricter customer knowledge procedures. With reference to section 17 of the Money Laundering Act, the Danish FSA also instructs the company to carry out stricter customer due diligence procedures in customer relationships where the company has assessed that there is an increased risk of money laundering and terrorist financing, including obtaining information on the origin of the funds if necessary.
The company is instructed to ensure that the company has business procedures to determine whether the customer, the customer’s real owner, is a politically exposed person or a close or close business partner of a politically exposed person.
The company is ordered to ensure that customer due diligence procedures are carried out when a customer’s relevant circumstances change and otherwise at appropriate times stipulated in the company’s business procedures so that the company’s information about customers is continuously updated.
The company is instructed to
The company is instructed to ensure that written business procedures are prepared for how the company will, with appropriate frequency, carry out internal controls that ensure that the company effectively prevents, limits and manages the risk of money laundering and terrorist financing. The company is also required to ensure that the company performs the internal inspections, including that there is documentation for the inspections performed.