Statement on money laundering inspection in Mozipo ApS
In October 2019, the Danish Financial Supervisory Authority carried out an inspection of Mozipo ApS (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 due diligence procedures and customer monitoring. Finally, the inspection included the company’s inspection, listing, notification and storage obligations.
Risk assessment and summary
Mozipo ApS is part of an international group with Mozipo Holding LTD. as the parent company, headquartered in Cyprus. Mozipo Holding LTD has subsidiaries that are present in various countries, such as Lithuania, Poland and Romania. The company offers smaller consumer loans to private customers via the Internet. The company does not offer other products. The Danish Financial Supervisory Authority considers that the company’s inherent risk of being used for money laundering or terrorist financing was normal. The Danish FSA’s assessment was i.a. based on the fact that the company only offered a single financial product to private customers residing in Denmark.
Based on the inspection, there are some areas that give rise to supervisory reactions. In view of the time that has elapsed since the inspection, the Danish Financial Supervisory Authority is aware that conditions may have changed significantly. The company has been instructed to revise its risk assessment to include 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, and addresses the risk of the company being used for money laundering and terrorist financing separately.
The company has also been instructed to revise the company’s money laundering policy so that the policy is based on the company’s risk assessment and sets the company’s overall strategic goals in the money laundering area, and that it contains the principled decisions on how the company should be organized so that the risks of money laundering and financing terrorism countered. The company has also been instructed to ensure that it checks the identity information of all the company’s customers on the basis of documents, data or information obtained from a reliable and independent source. The company has been instructed to obtain and store sufficient information about the purpose of the customer relationship and its intended nature.
The company has been instructed to ensure that it carries out the necessary monitoring of established business relationships with the company’s customers, including of 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 continuously updated. The company has been instructed to ensure that it has procedures to determine whether customers at the establishment of a customer relationship or during an ongoing customer relationship are or will be politically exposed persons or close or close partners of a politically exposed person.
The company has been instructed to prepare written procedures for how the company will carry out internal controls with appropriate frequency and 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 the checks carried out. Finally, the company has been ordered to appoint a money laundering officer who has the authority to make decisions on behalf of the company in accordance with the provisions of the Money Laundering Act.