Statement on inspection in Skjern Bank A / S (money laundering area)
In October 2021, the Danish Financial Supervisory Authority inspected Skjern Bank A / S. The inspection was an investigation of the money laundering area. The inspection included the bank’s organization, risk assessment, policy and written business procedures in the money laundering area.
In addition, the inspection included the bank’s customer knowledge and monitoring as well as the bank’s compliance with the investigation, listing, notification and storage obligations and the requirements for internal controls in the area.
Risk assessment and summary
The bank is a Danish bank with branches in Skjern, Esbjerg, Bramming, Ribe, Varde, Hellerup and Virum with approx. 180 employees. The bank offers traditional financial products such as deposits and loans, credits, box rentals, cash handling, currency and cross-border payments as well as a wide range of mortgage, investment, pension and insurance products as well as leasing of e.g. vehicles and larger machines to the bank’s customers.
The Danish FSA estimates that the bank’s inherent risk of being used for money laundering or terrorist financing is medium to high. The Danish FSA’s assessment is i.a. based on the bank’s offering of a number of financial products, e.g. with the option of cross-border payments and cash handling. Furthermore, the Danish FSA’s assessment is based on the bank offering box rental with access to the boxes without the bank’s involvement.
Based on the inspection, there are a number of areas that give rise to supervisory reactions.
The bank has been instructed to revise its written business procedures so that the bank ensures that the business procedures clearly state when and in which situations the bank’s advisers must obtain information and documentation of the customers ‘funds’ origin and assets.
The bank has been ordered to carry out customer knowledge information when a customer’s relevant circumstances change and otherwise at appropriate times in accordance with the Money Laundering Act, section 10, no. 1.
The bank has also been instructed to ensure that the function of the monitoring system for suppressing alarms is only used to a limited extent and on a sufficient basis, and that sufficient control is made over the decisions on suppression and of the suppressed alarms themselves, cf. section 11 of the Money Laundering Act. , PCS. 1, No. 5.
In addition, the bank has been instructed to ensure that the bank’s notification of suspicious transactions to the Money Laundering Secretariat takes place immediately.