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Finanstilsynet Inspection Report: Lake Exchange ApS

Statement on inspection in Lake Exchange ApS (money laundering area)

In November 2020, the Danish Financial Supervisory Authority inspected Lake Exchange ApS. 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 and monitoring of private and business customers

Risk assessment and summary

The company has a permit for currency exchange pursuant to section 41 of the Money Laundering Act. The company offers currency exchange to private customers and corporate customers. 

The company consists exclusively of the director. So far, the company only has private customers in the portfolio. The customers are primarily occasional customers, such as tourists who need to exchange currency. 

The Danish Financial Supervisory Authority assesses that the company’s inherent risk of being misused for money laundering or terrorist financing is high. The Danish FSA’s assessment is based on the assessment of the inherent risk of money laundering and terrorist financing, which is associated with currency exchange activities.  

Based on the inspection, some areas have given rise to supervisory reactions.

The company is ordered to ensure that the risk assessment addresses the company’s risk of being used for money laundering and terrorist financing separately. 
The company is instructed to ensure that the company’s money laundering policy adequately reflects the company’s specific risk profile, including the company’s risk assessment. In the policy, the company must set the overall strategic goals in the area of ​​money laundering and contain the principled decisions on how the company must be organized so that the risks of money laundering and terrorist financing are met.


Inspection Report

Categories: Anti-Money Laundering Finanstilsynet Updates Inspection Reports


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