Order to Cashpoint Limited on adjustment of risk assessment cf. section 7(1) of the Anti-Money Laundering Act and two reprimands for an insufficient risk assessment and failure to prepare business procedures, cf. section 7(1) of the Anti-Money Laundering

Order (a) is issued due to a failure to assess the inherent risk of being abused for the purposes of money laundering and financing of terrorism, since the risk assessment is prepared in consideration of the mitigating measures. 

Reprimand (a) is given because Cashpoint Limited has not made a sufficient identification of all relevant risks related to types of customers, products, and payment methods, which is why the risk assessment did not reflect the business model. 

Reprimand (b) is given because the business procedures did not sufficiently describe how, when and by whom specific activities were to be performed to ensure compliance with the legislation. 

The Danish Gambling Authority notes that the rules on risk assessment and business procedures ae fundamental parts of the Anti-Money Laundering Act. Breaches of the rules lead to an order or a reprimand or in cases of serious or repeated breaches they lead to a report to the police.  

The order entails an obligation for Cashpoint Limited to act since they must submit an updated risk assessment which addresses the identified failure. 

The reprimands do not entail an obligation to act, since Cashpoint Limited has already sent an updated risk assessment with risk scenarios and updated business procedures.