Statement on inspection in Creditstar Denmark ApS (money laundering area)
In October 2019, the Danish Financial Supervisory Authority inspected Creditstar Denmark ApS. The inspection was an investigation of the money laundering area. The inspection included the company’s organization in the money laundering area, the company’s risk assessment, policies, business procedures and internal controls, as well as customer due diligence procedures, including monitoring of private and business customers.
Risk assessment and summary
The company offers short-term loans to private individuals residing in Denmark. The company is part of the Creditstar Group, which is based in Estonia. The Creditstar Group is established in eight European countries, including Denmark.
The Danish Financial Supervisory Authority assesses that the company’s inherent risk of being used for money laundering or terrorist financing is normally 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 company offering a single financial product and that the product is only offered to private customers resident in Denmark. Conversely, the company’s customer portfolio consists exclusively of distance customers.
Based on the inspection, there were a number of areas that gave rise to supervisory reactions.
The company was instructed to revise its risk assessment so that it deals separately with the risk of money laundering and terrorist financing based on the company’s business model, and which on that basis includes an assessment of the risk factors associated with the company’s customers, products, services and transactions as well as supply channels and countries or geographical areas.
The company was instructed to prepare a money laundering policy, which is based on the company’s risk assessment and sets the company’s overall strategic goals in the area 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 are countered.
The company was ordered to ensure that all the company’s customers’ identity information is checked on the basis of documents, data or information obtained from a reliable and independent source, and that this can be proven to the Danish Financial Supervisory Authority.
The company was instructed to ensure that sufficient information is obtained and stated about the purpose and intended nature of the customer relationship, and that this can be proven to the Danish Financial Supervisory Authority.
The company was also instructed to ensure that a risk assessment of customer relationships is carried out, including an assessment of whether the customer is a politically exposed person, so that the company can carry out a correct customer knowledge procedure.
The company was instructed to ensure that it carries out the necessary monitoring of established business relationships with the company’s customers, including politically exposed persons, in order to assess whether the customers’ transactions are in accordance with the company’s knowledge of the customers and that information about the customer is ongoing. updated.
The company was instructed to carry out stricter customer due diligence procedures in the customer relationships where the company has assessed that there is an increased risk of money laundering and terrorist financing, including in customer relationships with politically exposed persons, and if necessary to obtain information on the origin of the funds.
The company was instructed to ensure that the company investigates suspicious transactions and that the results of these investigations are recorded and stored.
The company was instructed to ensure that the Money Laundering Secretariat is notified when identifying suspects or when the company has reasonable grounds to believe that a transaction, funds or activity has or has been linked to money laundering or terrorist financing.
The company was instructed to ensure that the company carries out internal controls 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 checks carried out.
Finally, the company was instructed to appoint a money launderer associated with the company who has sufficient knowledge of the company’s risk of money laundering and terrorist financing to be able to make decisions that may affect the company’s risk exposure, and to ensure that the establishment and continuation of a business relationship with a politically exposed person is approved by the money launderer.