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Finanstilsynet Inspection Report: FLEASING A/S

Statement on inspection in FLEASING A / S (money laundering area)

In March 2020, the Danish Financial Supervisory Authority conducted a virtual inspection of FLEASING 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 offers various financial leasing products to private and business customers. The company’s core products consist of leasing cars, ie. flex leasing for private individuals, flex leasing for traders, operational leasing for traders, split leasing and seasonal leasing. The company’s registered car fleet is predominantly cars in the luxury segment.

The company offers financial leasing in Denmark from the company’s address. The company only serves customers residing in Denmark and only receives cash payments to a limited extent. 

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 assessed in relation to the average of financial companies in Denmark. In the assessment, the Danish Financial Supervisory Authority has placed particular emphasis on the fact that leasing companies are generally considered to have an increased inherent risk of being used for terrorist financing [1] . Conversely, the company only accepts cash payments to a limited extent, just as the company’s customers only consist of customers residing in Denmark who are physically present with the company when establishing the customer relationship.

Based on the inspection, a number of areas have given rise to supervisory reactions.

The company is ordered to ensure that the company’s money laundering policy adequately reflects the company’s specific risk profile, including the company’s business model and risk assessment, cf. the Money Laundering Act, section 8, subsection. 1.

The company is instructed to ensure that it obtains identity information on all the company’s customers, including that legal persons obtain information on real owners in order to ensure sufficient customer knowledge of the customers, and that information is obtained on the purpose and intended nature of the customer relationship , where this is relevant, cf. the Money Laundering Act, section 11, subsection 1, Nos. 3 and 4.

The company is ordered to ensure that the company records and stores the results of investigations of suspicious transactions carried out in accordance with the duty to investigate in the Money Laundering Act, section 25, subsection. 1 and 3.

The company is reprimanded for not having prepared a written risk assessment, cf. the Money Laundering Act, section 7, subsection. 1, as well as written policies and business procedures, cf. the Money Laundering Act, section 8, subsection 1, before 9 December 2019.

Link:

Inspection Report

Categories: Anti-Money Laundering Enforcement Actions Finanstilsynet Updates Inspection Reports Reprimand

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