"If things aren't documented, they haven't been done"
- Ghazwan Cheikh Youssef - Owner, CY REvision
CY revision recently completed a successful money laundering inspection from the Danish Business Authority
Ghazwan Cheikh Youssef, owner of CY Revision, approached the assessment with peace of mind, feeling confident that Creditro had him covered.
CY Revision is on cloud nine, following a successful inspection by the Danish Business Authority. It went completely by the book and the owner is now sharing his dos and don'ts – and assures his colleagues that the big bad wolf isn't all that bad, if you just lay your bricks right.
”If you make sure all of your things are in order and you can document everything accordingly, then the entire process will be a small mountain to climb,” says Owner of CY Revision, Ghazwan Cheikh Youssef.
Approached with confidence
CY Revision has been a Creditro customer since September 2021, and they met the Danish Business Authority with peace of mind.
”We knew what Creditro is capable of. That's also why we switched to Creditro from the previous platform we used,” says Ghazwan. He also highlights Creditro's search for negative media coverage as a feature that provides additional support for the final risk assessment, which auditors have to account for.
"On top of what you are legally obliged to document, Creditro provides extra features, which contribute to us having a great gut feeling about the software that we have implemented – and the tool that we have used. It has been helpful for is in completing this inspection."
Knowing your KYC is not enough
CY Revision received a notification letter from the Danish Business Authority four weeks before the audit. Ghazwan handed over an active customer list, internal policies, and documentation of staff training.
”The duty of notification comes into play when you cannot contest that something seems suspicious. You can't wait for the client or citizen to either violate the Anti-Money Laundering Act or be at a level of suspicion. The policies help to cover that area and set the stage for those scenarios.”
Meticulous review
The Danish Business Authority slavishly reviewed the selected reports, which included both existing and former customers, as it is a requirement to keep documentation for five years.
"The Danish Business Authority meticulously enquired about customers, and then we went through the list. After all, we know our customers pretty well, so we informed them what type of customers we have, what they do and what types of development there has been in the company," explains Ghazwan and adds:
”Next step is documentation. We used Creditro as our foundation and looked up the customer (on the platform ed.), where we had all the documentation we needed.” He elaborates that part of the documentation is not only to show that you have obtained the necessary documentation, but it is also being able to document when the information has been obtained.
Document it or it didn't happen
Ghazwan's advice for his industry colleagues is simple: take the Anti-Money Laundering Act seriously, know your customers and consider whether your way of handling your documentation is the right one.
"If you don't have that many customers, it may well be that you can store documents manually and without a software program. It is easy (with software ed.) to administratively document when the various customers have joined, when they have been cancelled, when you have received answers to the various questions, and when you saved the ID. It is also part of the inspection," he says, adding:
”In my industry they say: if things aren't documented, they haven't been done."
What happens at an inspection?
Notification letter
The company is notified as a rule 4 weeks before the inspection itself. The notification letter will state who is participating from the Danish Business Authority, and also provide an expected time estimate for the inspection visit.
Preparation
In the notification letter, the Danish Business Authority requests the company to submit an account of the company's commercial activities, a customer list, and the company's risk assessment according to Section 7 of the Anti-Money Laundering Act, as well as written policies, procedures, and controls according to Section 8 of the Anti-Money Laundering Act, before the inspection visit.
The inspection
On the day, the company's knowledge of and compliance with the Anti-Money Laundering Act is reviewed, as well as guidance on the rules of the Anti-Money Laundering Act. Several customer cases will also be selected for review.
First ruling - draft
The Danish Business Authority sends a draft decision to the company, so the company can check whether the factual information is correct. The company also has the opportunity to make comments. The company receives the Danish Business Authority's draft decision in its e-Boks.
The final ruling
The company receives the final ruling in its e-Boks, including the legal justification for the decision also appears.
*NOTE. The Danish Business Authority is authorised to conduct unannounced inspection visits, meaning inspections without a notification letter can occur.
