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Finanstilsynet Inspection Report: Den Jyske Sparekassen A/S

Statement on inspection in Den Jyske Sparekasse A / S (money laundering area)

In July 2020, the Danish Financial Supervisory Authority inspected Den Jyske Sparekasse A / S (the savings bank). The inspection was an investigation of the money laundering area. The inspection included the bank’s risk assessment, policies, procedures and internal controls. In addition, the inspection included the bank’s customer due diligence procedures, monitoring of private and business customers. Finally, the inspection included the bank’s duty of investigation, listing, notification and storage.

At the time of the inspection, Sparekassen was a locally based bank with branches in South and Central Jutland. Sparekassen offered the usual non-complex products to private customers and business customers, typically smaller business companies. The majority of the bank’s customers were affiliated with the bank’s local area. Following the inspection, Den Jyske Sparekasse has been merged with Vestjysk Bank. The merger took effect on 13 January 2021. The new, merged bank is called Vestjysk Bank and now constitutes Denmark’s 8th largest bank.

The Danish Financial Supervisory Authority assesses that Sparekassen’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 special emphasis on the Savings Bank offering a number of financial products to both private customers and business customers. Conversely, Sparekassen limits its business to traditional financial products and is primarily based in its local area with customers who mainly live in Denmark.

Based on the inspection, there are some areas that give rise to supervisory reactions.

Sparekassen is instructed to ensure that it is in possession of sufficient customer knowledge information regarding identity information on the real owners of legal entities, including Sparekassen’s association customers, and information on the purpose and intended nature of the customer relationship, where relevant.

In addition, Sparekassen is instructed to ensure that it conducts sufficient investigations of alarms from Sparekassen’s monitoring of customers’ transactions. Below, the savings bank must document and store the results of these surveys.

Sparekassen is instructed to ensure that Sparekassen’s monitoring system covers and can apply changes in customer behavior and deviations from Sparekassen’s knowledge of the customer to generate alarms

Finally, for the period since the beginning of 2020 to date, Sparekassen will be instructed to investigate whether a high de minimis threshold in the monitoring system prevented alarms regarding unusual transactions or behavioral changes that should have led to an investigation and, if so, to investigate these in order to determine whether notification is to be made


Inspection Report

Categories: Anti-Money Laundering Due Diligence Finanstilsynet Updates Inspection Reports


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