Statement on inspection in Axcel Management A/S (laundry area)
In June 2022, the Danish Financial Supervisory Authority inspected Axcel Management A/S (the company). The inspection was an investigation into the money laundering area. The inspection included the company’s organization, policy, written procedures and internal controls in the area of money laundering. In addition, the inspection included the company’s customer knowledge and monitoring of customers as well as investigation of alarms and notification to the Money Laundering Secretariat.
Risk assessment and summary
The company is a manager of alternative investment funds (FAIF) that offers investment advice and capital investment. The company acts as adviser and administrator for a wide circle of Danish and foreign investors who invest in Nordic companies. The company currently manages three funds, each consisting of three alternative investment funds (AIF).
The company’s customers include banks and financial institutions, pension and life insurance funds, private investors and others, mainly from Nordic countries. None of their customers are residents of high-risk countries.
The Danish Financial Supervisory Authority assesses that the company’s inherent risk of being used for money laundering or financing terrorism is average in relation to the average of financial companies in Denmark. In the assessment, the Danish FSA has taken as its point of departure that the company’s clientele consists of many different types of customers, including complex ownership structures.
Based on the inspection, there are a number of areas which give rise to supervisory reactions.
The company has been ordered to revise its risk assessment, so that the risk assessment uncovers the company’s risks separately for money laundering and terrorist financing.
At the same time, the company has been ordered to ensure that the company carries out a risk assessment of its customers, which includes to a greater extent all relevant information obtained about the customer, so that the customers are correctly risk classified as either low, medium or high risk on the basis of a concrete and documented assessment and that the company can carry out a correct customer due diligence procedure and that this can be reimbursed to the Danish Financial Supervisory Authority.
The company has also been ordered to ensure that the company updates documents, data or information about the customer.
The company has also been ordered to carry out stricter customer due diligence procedures in cases where the company assesses that there is an increased risk of money laundering and terrorist financing.
The company has also been ordered to revise its written business procedures, so that these contain descriptions of the specific activities that the employees must carry out.
Finally, the company has been ordered to ensure that it reports correct information that is necessary for the FSA’s risk assessment of companies and individuals.