As Section 8 of the Anti money Laundering Act demands financial service providers to have a written policy and procedures of combating Money Laundering and terrorist financing in their businesses. A B&B Financial Services APS have drawn up an AML policy to help control and monitor financial transactions to identity suspected financial transaction. This will give us the opportunity to come up with decision to prevent money laundering and terrorist financing. This will be referencing the 4th Money Laundering Directive: Article 8, subsection 3 and 4.
The company is also registered with the Danish Business Authority and the Danish Tax Authority as a Money Transfer Company with a CVR No: 44005050. It will as well be observing the money Laundering guidance of the Danish Financial supervisory Authority to adhere to money laundering act reference to the money laundering act, section 3 and reference to the 4th money laundering Directive: Article 1, section 3 of the Danish Government.
B&B Financial Services APS developed a company policy that would warrant us and our customers to comply with Governments Regulations as a financial service provider. The following regulations are to be complied with:
It is against the law to use 500 euro note as a service provider and this ban includes both private individuals and companies. The ban is specified in section 6 of the money laundering act. The 500 euro note is ban in Denmark and it must not be use in any form of transaction. It must not be paid in or out as a mean of transaction in Denmark. The 500 euro note can be used in other European countries but it is not allowed to use it in Denmark for any transaction. B&B Financial Services APS will not allow its customers with 500 Euros note to use their services.
Terrorist financing is stipulated in section 4 of the money laundering act and thisvinformation has no difference with the information in section 114 of the criminal code which defines terrorist financing as:
Providing support for the terrorist directly or indirectly.
Collecting funds for the terrorist directly or indirectly, etc.
B&B Financial Services APS as a service provider will not allow or entertain customer who are partially or actively involved into terrorist financing. The company will have its due diligence mechanisms in place to know our customers and what activities they are involved in or who they are sending money to. Our target market is working class people who will be providing their pay clips on some occasion to vet their source of income and financial situation.
As stipulated in section 6 of the money Laundering act and with reference to other legal documents especially Article 6, subsection 1, of the council Regulation 2009/44/EC of 18 December 2008. This articles and sections describe mechanism to protect the euro from be counterfeited by people and criminals. As B&B Financial Services APS will be sometimes handling banknote and coins, it will be the concern of the company to have detectors to identity counterfeits and report it to the authorities to stop the circulations of counterfeits in the financial system.
B&B Financial Services APS as a financial institution will always identify and access risk attach to every customer and financial transaction. As we have to know the customers we are dealing with, the first point of accessing the customer is by identifying the customer and his/her purpose of being our customer. By trying to know his purpose of doing business with us, will give us the opportunity identify who he is and the risk of doing business with the customer. B&B Financial Services APS as a company will gather as much information as possible on the customers and transaction to identify any potential risk. We as a company also will abide by all the risk factors under Section 7, subsection 1 of the Money Laundering act.
B&B Financial Services APS as a financial service provider has to know the kind of customers we are dealing with to be able to assess the risk attached. As section 7 of the money laundering act is looking at the company’s risk factor whiles section 11 assesses the company’s customers. As section 13 of the act concentrate on the due diligence procedure, we will incorporate both sections in our due diligence procedure to have a very understanding of the type of customer we are dealing with and to understand the risk factors attach in dealing with the customer.
B&B Financial Services APS as a financial service provider in the remittance business, knows there might be customers who would want to use our product and services to launder elicit funds likewise any other payment service provider. That is why we have a very robust system which’s compliance system will detect any red flag transaction that is created in the system. We also wet our customers to know more about the job or businesses once they start using our services. B&B Financial Services APS do not allow third party payment and our partners as well do not allow third party recipients, except if the third party appears in person with the sender with proper identification.
B&B Financial Services APS as a remittance company will want to create services for different people in different African countries. At the moment we will be only focus on transactions from Denmark and some EU countries to the West African countries. It will be our concern to understand the purpose of the transactions. As we will be dealing with different companies as partners in these West African countries, we will do our due Diligence on these companies and and also review their AML policy weather it is in line with Money Laundering policy of their domicile country and African union. We will monitor transactions that are going to high risk countries and always request source of funds from customers if the transaction is suspicious.
B&B Financial Services APS will always update our companies risk assessment which will give us the opportunity to meet our companies risk assessment profile. The updating will be done every six months to assess risk and make sure that our transactions are in line with Financial Supervisory Authorities guideline and regulations. Any time B&B Financial Services APS is adjusting its business model to incorporate other financial services; this will go simultaneously with updating the risk assessment of the company.
Based on B&B Financial Services APS business model, a risk management mechanism will be put in place in the area of money laundering to spot out risky and red flag transactions. We are very much aware that criminal can take advantage of our services to send transactions which are criminal in nature. Our sophisticated money transfer system has a compliance system which will spot red flag transactions and we will have a compliance team to follow up on suspicious transactions and get the right proofs to justify the legitimacy.
B&B Financial Services APS will be considerate and vigilant when it comes to hiring of staffs. We will have screening policy of our staffs to make sure that; they will not abuse their position to embark on money laundering and terrorist financing. We will screen them base on their previous life criminal records and to find out if they have been previously fired for any misconduct or financial malpractice in any country. We also have to make sure that they are not previously convicted of crimes related to money laundering or crimes that will be risky for our company.
We are under the law to report all suspicious transactions to the Financial Supervisory Authority or report to the nearest police station to avoid money laundering and financing criminal Activities. This will help the law enforcement agencies to combat money laundering and terrorist financing.
We are obligated to keep customers records and Transaction for a period of Three years (3). Transactions of the customers will be kept for a period of 3 year in case a request is made on the customer’s transaction documents by the Authorities. These records in a form of a soft copy will be available in our software or system as long as we are using the same system. This will make it easy to provide the reports any time they are demanded by the Authority.
Sending a Transaction on behalf of someone would require identification from both the third party and the sender of the transaction. In this situation the third party have to be present to identify himself in person. This will give us the opportunity to store information’s on both parties for future referencing.
The company in its name is required to have a compliance officer to monitor suspicious and fraudulent transactions. We are to adhere to the regulations of The Financial Supervisory Authority and the Danish Business Authority and the following link will help you to get more ideas on Money Laundering.
https://www.dfsa.dk
https://danishbusinessauthority.dk/
You can also call the Danish Financial Authority or email them on the following contact details below.
+45 33 55 82 82
finanstilsynet@ftnet.dk
It is a requirement to acquire identification for every customer regardless of the amount. Every customer must provide a valid identification. The identification will give us the opportunity to do background check on the customer. It will also proof the legality of the customers and his residence status in case of any future development relating to money laundering and terrorist financing.
Consult Google for suspicious name and surname
Report suspicious transactions to the Authorities for further clarification.
Acquire Salary Slips and financial statements for huge transactions.