Statement on inspection in AP Pension Livsforsikringsaktieselskab (money laundering area)
In November 2020, the Danish Financial Supervisory Authority carried out an inspection of AP Pension Livsforsikringsaktieselskab (the company). The inspection included the company’s risk assessment, policies, procedures and internal controls in the area of money laundering. In addition, the inspection included the company’s customer knowledge procedures and monitoring of private and business customers. Finally, the inspection included the company’s compliance with the inspection, listing, notification and storage obligations.
Risk assessment and summary
AP Pension is the fourth largest commercial pension company in Denmark. The company takes out company pensions and privately subscribed pension schemes and also offers risk insurance and savings products. AP Pension has acquired the Swedish pension company Skandia’s Danish pension business from 1 January 2019, and the companies are currently being merged. It is noted that the inspection only concerns the originally Danish company AP Pension.
The Danish Financial Supervisory Authority assesses that the company’s inherent risk of being used for money laundering or terrorist financing is low, 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 the company mainly offers company pension schemes, voluntary company schemes and privately subscribed pension schemes in Denmark. However, it should be noted that the company also has pension schemes, including the so-called § 53 a schemes, which the company has classified as medium-risk products.
Following the inspection, a number of areas have given rise to supervisory reactions.
The company is instructed to revise the company’s risk assessment so that it identifies and assesses the risk that the company will be used for money laundering and terrorist financing.
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 business model and risk assessment.
The company is instructed to prepare business procedures in a number of areas where there are currently no business procedures, so that these include all relevant risk areas in the company. Likewise, the company must revise its business procedures so that these are sufficiently operational and clearly state the specific tasks that the employees must perform.
The company is ordered to ensure that it obtains sufficient identity information on all the company’s customers, including that for legal persons it obtains information on real owners in order to ensure sufficient knowledge of the customers and address information on foreign customers.
The company is also instructed to carry out a risk classification of all its customers and then carry out stricter customer awareness procedures for all customers, where the company may assess that there is an increased risk of money laundering or terrorist financing.
The company is also instructed to ensure that the company continuously monitors established business relationships, including transactions carried out as part of a business relationship, to ensure that the transactions are in accordance with the company’s knowledge of the customer and the customer’s business and risk profile, including if necessary. the origin of the funds and to investigate any potentially suspicious transactions.
Finally, 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.