Statement on inspection in Nordea Kredit Realkreditaktieselskab (money laundering area)
In June 2022, the Danish Financial Supervisory Authority inspected Nordea Kredit Realkreditaktieselskab (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 100% owned subsidiary of Nordea Bank Abp. The company is licensed as a mortgage credit institution and offers mortgage loans through Nordea Bank’s branch network. The company has outsourced most activities and tasks within the Financial Crime area to Nordea Denmark, including customer familiarization procedures, screening of employees and customers, sanction handling, customer contact, customer exit, notifications to the Money Laundering Secretariat, etc.Finanstilsynet Inspection Report
The Danish FSA assesses that the company’s inherent risk of being used for money laundering or terrorist financing is medium. The Danish Financial Supervisory Authority assesses that, although mortgage loans are an area that as such is not suitable for money laundering or terrorist financing, there is a certain risk of using mortgage loans for money laundering.
The assessment is also based on the company’s size and a high exposure to high-risk industries.
Based on the inspection, there are a number of areas which give rise to supervisory reactions.
The company has been ordered to adapt its written business procedures so that they contain descriptions of the specific activities that employees must carry out in connection with handling suspicious or unusual transactions, which must be notified to the Anti-Money Laundering Secretariat.
At the same time, the company has been ordered to assess and, where relevant, update information on the origin of the funds for customers who are not customers of the parent company, in the ongoing customer due diligence procedure.
The company has also been ordered to investigate suspicious transactions without undue delay in order to ensure an immediate notification to the Anti-Money Laundering Secretariat. The company must ensure that the results of these investigations are recorded and stored.
Finally, the company has been ordered to conduct adequate internal controls on the company’s investigations of unusual transactions to ensure that the investigations are conducted in a timely manner and to ensure that the outcome is adequately recorded.