March 16, 2016
Introduction
In 2015, the Danish Financial Supervisory Authority (the FSA) conducted an inspection to establish
whether Danske Bank was in compliance with the current rules in the anti-money laundering (AML)
area.
Risk assessment
Danske Bank is the largest financial institution in Denmark. Danske Bank Group conducts a large volume of financial business, including transactions in the fields of asset management, investment, pensions, mortgage finance, insurance, real estate brokerage and leasing. The bank has a substantial number of personal, business and institutional customers, and many have a complex group structure. A large number of customers reside or are domiciled outside Denmark, and a large number of physical customers are distance customers. Transaction volumes, including cross-border funds transfers, are substantial. A great many customer transactions are made online or by means of cash handling in connection with account deposits, foreign exchange and funds transfers. The bank has a significant number of correspondent banks throughout the world. In keeping with international guidelines, cross-border correspondent bank relationships are considered to involve a high risk of money laundering and terrorism financing. Against the background of the extent and nature of these activities, the FSA considers Danske Bank’s
inherent risk of being exploited for money laundering or terrorism financing purposes to be high compared with the risk to which the average Danish financial institution is exposed.
Police report against Danske Bank
On the basis of the conclusions of the inspection, the FSA has reported the bank to the police for
violation of the provisions on correspondent bank relationships of the Danish AML Act, including for
non-compliance with the FSA’s order issued in the area in 2012.