Statement on inspection in Secure Payment A / S (money laundering area)
In February 2021, the Danish Financial Supervisory Authority carried out an inspection of Secure Payment A / S (the company). 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 the company’s customer knowledge procedures and the company’s monitoring of customers. Finally, the inspection included the company’s inspection, listing, notification and storage obligations.
Secure Payment A / S (the “Company”) offers escrow solutions, where the company offers a deposit of the purchase price in connection with the purchase and sale of used cars between traders via the auction platform Autoproff A / S.
The Danish Financial Supervisory Authority assesses that the company’s inherent risk of being used for money laundering or terrorist financing is low to normal. The Danish FSA’s assessment is i.a. based on company size, business model, products and customers. In its assessment, the Danish Financial Supervisory Authority has emphasized that the company has a relatively modest clientele.
Based on the material submitted by the company as well as information provided during the inspection, there are a number of areas that give rise to supervisory reactions.
The company has been instructed to revise its risk assessment so that it is based on the company’s business model and includes an assessment of the risk factors associated with the company’s customers, products, services and transactions as well as delivery channels and countries or geographical areas. In addition, the company must ensure that the risk assessment covers the company’s risk separately for money laundering and terrorist financing, and that the risk assessment is substantiated with relevant data and is based on the national and supranational risk assessments.
The company has been instructed to revise the company’s money laundering policy so that it is sufficiently based on the company’s risks, and sets the strategic goals in the field of money laundering, and contains the principal decisions on how the company should be organized so that the risks of money laundering and terrorist financing countered.
The company has been instructed to ensure that the company obtains identity information on all the company’s customers, including that the company obtains information about the customers ‘real owners, and that the company checks the real owners’ identity information through a reliable and independent source.
In addition, the company has been instructed to ensure that it conducts adequate investigations of alarms from the company’s monitoring, including that the results of these investigations are documented and recorded.
The company has been ordered to ensure that it notifies the Money Laundering Secretariat in case of suspicion, or when the company has reasonable grounds to suspect that a transaction, funds or activity has or has been linked to money laundering or terrorist financing.
Finally, the company has been ordered to carry out internal controls. The company has been instructed to prepare procedures for internal controls. The internal controls must include a description of procedures for how the company will, with appropriate frequency, carry out internal controls that ensure that the company effectively prevents, limits and manages the risk of money laundering and terrorist financing, and that the company can document that the controls have been carried out.