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Finanstilsynet Inspection Report: Agilease A/S

Statement on inspection in Agilease A / S (money laundering area)

In September 2021, the Danish Financial Supervisory Authority inspected Agilease A / S. The inspection concerned the money laundering area and included the company’s risk assessment, policies, procedures and internal controls. In addition, the inspection included customer due diligence procedures, monitoring of private and business customers as well as the company’s investigation, listing, notification and storage obligations.

Risk assessment and summary

The company runs a leasing business and offers financial leasing to private and business 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 an increased inherent risk of being used for money laundering and terrorist financing. 

The inspection has given rise to the following supervisory reactions:

The company has been instructed to revise the company’s risk assessment so that it identifies and assesses the risk that the company may be used for money laundering and terrorist financing. The risk assessment must be based on the company’s business model and on that basis include an assessment of the risk factors associated with the company’s customers, products, services as well as transactions and delivery channels. In addition, the company must ensure that the risk assessment covers the company’s risk separately for money laundering and terrorist financing, respectively. 

The company has been instructed to revise its business procedures so that they contain descriptions of the specific activities that the employees must perform. The business procedures must include risk management, customer due diligence procedures, including stricter customer due diligence procedures, investigation, listing, notification and retention obligations, screening of employees and internal control. 

The company has also been ordered to carry out a risk assessment of customer relationships, so that customers are risk-classified on the basis of a concrete and documented assessment. 

The company has also been instructed to investigate and have business procedures to determine whether the customers are or during the customer relationship become close or close partners of a politically exposed person. 

The company has also been instructed to investigate suspicious transactions, including recording and storing the results of these investigations, and to ensure that this can be proven to the Danish Financial Supervisory Authority. 

The company has also been instructed to notify the Money Laundering Secretariat on suspicion or when the company has reasonable grounds to believe that a transaction, means or activity has or has been linked to money laundering or terrorist financing. 

The company has also been ordered to establish a whistleblower scheme, where the company’s employees can report violations of the Money Laundering Act and rules issued pursuant to it via a special, independent and independent channel. 

Finally, the company has been reprimanded for not having had a risk assessment, a policy in the area of money laundering, written business procedures and internal controls in the area of money laundering before 2021.

Link:

Inspection Report

Categories: Anti-Money Laundering Finanstilsynet Updates Inspection Reports

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