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FINANSTILSYNET
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April 17, 2013
File 62122/ee-0001
Finantsinspektsioon
Business Conduct Supervision Division
Sakala4
15030 Tallinn
Estonia
Dear Colleagues,
_{)e_as-
Danske Bank, Estonia Branch -
EFSA's Memorandum ofMarch
12, 2013
Finanstilsynet refer to EFSA's Memorandum of March 12, 2013, concerning
Danske Bank's Branch in Estonia.
According to the Memorandum, EFSA has obtained information from
various indicators that the Branch may not have correctly undertaken the
customer due diligence measures and therefore may have violated the
Estonian AMUCTF Aet. On the basis of these indicators, which are
explained in the Memorandum, EFSA concludes that further supervisory
procedures must be taken in order to prevent the Branch from being used
for money laundering and terrorist financing purposes.
We recall that similar concerns were raised by EFSA in 2012. In the light
hereof Finanstilsynet asked Danske Bank to comment. The Bank responded
to this request by letter of April 3, 2012, from the Bank's Executive Board
Secretariat/Group Compliance & AML. This letter comprised a rather
comprehensive explanation of the Bank's policies and procedures aimed at
mitigating MUTF risks related to customers defined by the Bank as high risk
customers of its Estonia Branch, including non-resident natural persons and
entities. Finanstilsynet forwarded copy of Danske Bank's letter of April 3,
2012, to EFSA by letter of July 3, 2012.
It follows from EFSA's Memorandum of March 12, 2013, that EFSA carried
out an off-site inspection of the Branch in October 2012. Finanstilsynet is
interested in leaming more about the scope of the outcome of this
inspection.
Finanstilsynet takes the concerns raised by EFSA very seriously and have
noted EFSA's call for further supervisory measures. Such measures should
probably include an on-site inspection at the premises of the Branch and a
DANISH FINANCIAL
SUPERVISORY AUTHORITY
Aarhusgade 110
2100 Copenhagen
Danmark
+45 33 55 82 82
Tel
Fax +45 33 55 82 00
www.dfsa.dk
MINISTRY OF 9USIN11!SS AND
GROWTH