Statement on inspection in Fleggaard Leasing A / S (money laundering area)
In January 2021, the Danish Financial Supervisory Authority inspected Fleggaard Leasing A / S. 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 private and business customers.
Risk assessment and summary
The company is registered in accordance with section 48, subsection 1 of the Money Laundering Act, as the company offers financial leasing to private and business customers, including private leasing, business leasing and flex leasing. The company primarily has customers residing in Denmark. The company cooperates with a number of Danish car dealers, where the dealer offers financial leasing agreements to its customers, which are financed via Fleggaard Leasing A / S.
The Danish Financial Supervisory Authority assesses that the company’s inherent risk of being misused 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 fact that leasing companies are generally considered to have an increased inherent risk of being used for terrorist financing. Conversely, the company does not accept cash payments, just as the company’s customers primarily consist of customers residing in Denmark.
Based on the inspection, there are a few areas that give rise to supervisory reactions.
The company is instructed to ensure that the company conducts stricter customer due diligence procedures in the customer relationships where the company assesses that there is an increased risk of money laundering and terrorist financing, and to ensure that the company prepares written business procedures for how the company conducts stricter customer due diligence procedures.
In addition, the company is instructed to ensure that the company carries out internal controls in all significant areas with appropriate frequency, which ensures that the company effectively prevents, limits and manages the risk of money laundering and terrorist financing, and that the company can document the controls carried out.