Statement on inspection in Grenkeleasing ApS
On 22 April 2021, the Danish Financial Supervisory Authority inspected Grenkeleasing ApS. The inspection was an investigation of the money laundering area. The inspection included an examination of the company’s risk assessment, policies, business procedures and internal controls as well as the company’s customer knowledge, including monitoring of 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. The company was established in Denmark in 2002 and is 100% owned by the German company Grenke AG.
The company offers leasing of a wide range of products such as. tools, machines, cash register systems, media technology equipment, coffee machines, IT equipment and software. The company cooperates with dealers in Denmark who sell the above products. The company also sells to a lesser extent directly to the company’s customers.
The Danish Financial Supervisory Authority assesses that the company’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 fact that leasing companies are generally considered to have a high inherent risk of being used for terrorist financing and that the company’s sales take place via distance selling.
Following the inspection, a number of areas have given rise to supervisory reactions.
The company has been instructed to prepare adequate business procedures for risk management, customer due diligence procedures, investigation, listing and notification obligations, storage of information, screening of employees and internal control.
The company has been ordered to ensure that the company carries out a risk assessment of customer relationships, so that the customers are risk-classified on the basis of a concrete and documented assessment.
The company has been ordered to ensure that the company identifies and obtains sufficient identity information on the real owners of legal entities in order to ensure sufficient knowledge of the customers, and that this can be proven to the Danish FSA.
The company has been instructed to ensure that the company assesses and, where relevant, obtains information about the purpose and intended nature of the business relationships.
The company has been ordered to ensure that the company carries out stricter customer knowledge procedures in the customer relationships where the company assesses that there is an increased risk of money laundering or terrorist financing.
The company has been instructed to ensure that the company investigates and has business procedures to determine whether the customers are or during the customer relationship become a politically exposed person or a close partner or close relative of a politically exposed person.
The company has also been instructed to ensure that the company investigates suspicious transactions, including that the results of these investigations are noted and stored, and that this can be proven to the Danish Financial Supervisory Authority.
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.
The company has been instructed to ensure that the company carries out internal controls to an appropriate extent, which ensures that the company effectively prevents, limits and manages the risk of money laundering and terrorist financing, including that the company can document the checks carried out.
Finally, the company has been reprimanded for not having a policy on money laundering before April 2021.