"If things aren't documented, they haven't been done"
- Ghazwan Cheikh Youssef - Owner CY REvision
KCY revision has just completed a thriving money laundering inspection from the Danish Business Authority
and owner and Master of "skat", Ghazwan Cheikh Youssef, went to the assessment with
peace of mind "we know what Creditro can do."
There is a good atmosphere at CY Revision, after a succesfull inspection by the Danish Business Authority. Now, the owner is giving Do's and dont's to his collegaues - and assures, that the big bad wolf is not so bad, if you just document your bricks.
”If you have your things in order and you can document it, then it's not a steep climb. You reach a point where you think: Don't you have more that we can review?,” Says the owner of CY Revision, and Master in Skat, Ghazwan Cheikh Youssef.
Went in with confindence
CY Revision has used Creditro since September 2021, and they met the Danish Business Authority with peace in mind.
”We knew what Creditro is capable of, and that was also why we moved to Creditro from the previous program we used,” says Ghazwan Cheikh Youssef, who points out Creditro's search for lousy media coverage as an additional feature that, in his eyes, helps to provide additional support for the final risk assessment, which the auditor must offer himself.
"There are small extra features that Creditro provides, in addition to what you are obliged to do, that have contributed to the fact that it is with a good and good gut feeling about the piece of software that we have lying around and the tool that we have used, that it has been able to help us go through this inspection."
Knowing your KYC is not enough
CY Revision received a warning letter from the Danish Business Authority four weeks before the visit with Ghazwan Cheikh Youssef, thus handing over an active customer list, internal policies, and staff training
”The notification duty, after all, comes into play when you cannot deny that something seems suspicious. It is not the first time that it has been seen that the customer, or the citizens, have either violated the Money Laundering Act or are at the level of suspicion. The written policies here uncover that ballpark and chalk the pitch up in the given situations.”
They went through slavishly
The Danish Business Authority "slavishly" reviewed the selected samples, which included both existing and former customers, as it is a requirement to keep documentation for five years.
"The Danish Business Authority asked customers, and then we went through the list. After all, we know our customers well, so we told what some types of customers are, and what it is that they do, and what types of development there has been in the company, top of mind," explains Ghazwan Cheikh Youssef and adds:
”Next step is to document. We used Creditro 100 pct as our guide and starting point and went in and looked up the customer (on the platform ed.), and then we had all the documentation we need.”
He elaborates that part of the documentation is not only to show that you had obtained the necessary documentation it is also to be able to document when obtained the information.
Document's or it didn't happen
Ghazwan Cheikh Youssef's advice is clear for his colleagues in the industry: take the 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 canceled when you have received answers to the various questions, and when you have saved the ID. It is also part of the control," he says, adding:
”They say in my industry that if things aren't documented, they haven't been done."
What happens at an inspection?
The company is notified as a rule 4 weeks before the inspection itself. In the notification letter to the company, it will be stated who from the Danish Business Authority is participating, and also an expected time estimate for the inspection visit.
In the warning 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 Money Laundering Act, as well as written policies, procedures, and controls according to Section 8 of the Money Laundering Act, before the inspection visit.
On the day, the company's knowledge of and compliance with the Money Laundering Act is reviewed, as well as guidance on the rules of the Money Laundering Act. Several customer cases will also be selected for review.
Verdict PT 1. – draft:
The Danish Business Authority first sends a draft decision to the company so that the company can check whether all 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-Box.
The final verdict:
The company receives the final decision in its E-Boks, where the legal justification for the decision also appears.
*NOTE. The Danish Business Authority has authorization for unannounced inspection visits, which is why inspections without a notification letter can occur.