Denmark: Financial System Stability Assessment with reports on - IMF

68disclosureProvide practical guidelines for customs officers to guide them in implementing thesystem.Maintain declaration records so that information is organized and readily usable,especially to track patterns of cross-border cash movement.Preventive Measures–<strong>Financial</strong> InstitutionsCustomer duediligence, includingenhanced or reducedmeasures(R.5– 8)Third parties andintroduced business(R.9)Record keeping andwire transfer rules(R.10 & SR.VII)Monitoring oftransactions andrelationships (R.11 &21)Suspicious transaction<strong>reports</strong> and otherreporting (R.13, 14, 19,25 & SR.IV)Cross BorderExtend the applicability of the new MLA to the Faroe Islands and Greenland.Align identification requirements to take also into account the circumstances setforth by SRVII in the case of wire transfers.Undertake an assessment of whether individual countries of the EU, or those <strong>with</strong>which the Community has entered into an agreement for the financial area, are incompliance <strong>with</strong> and have effectively implemented the FATF Recommendations,for purposes of exempting from proof of identity customers that are FIs located inthese countries.Adopt a general clear requirement for a FI to determine whether the customer isacting on behalf of another person and an obligation to take reasonable steps toobtain sufficient identification data to verify the identity of that other person.Limit to pooled accounts only the exemption from the CDD requirement where abeneficial owner has funds in an account maintained by a lawyer for a client.Have the MLA empower supervisory authorities to issue regulations in the area ofPEPs.Adopt provisions to require FIs to document the respective responsibilities of thecorrespondent and respondent institutions and determine if the respondent bank hasbeen the subject of a ML or FT investigation.Issue guidance/regulation relating to the types of documents which are to be verifiedduring the identification process.Place the obligation to immediately obtain the necessary information on the FI thatis relying on the third party.Restrict a FI’s privilege of relying on CDD carried out by third parties either bylimiting such reliance to those located in jurisdictions where the authorities havethemselves ascertained that the supervisory framework and CDD measures areFATF-compliant, or by requiring FIs to satisfy themselves on that score (whether ornot the jurisdictions are <strong>with</strong>in the EU or in a country <strong>with</strong> whom the Communityhas concluded a financial area agreement).Align the requirements for wire transfers <strong>with</strong> the international standard byextending them to incoming payments, to situations where there is no personalcontact and to situations where the sender has an account <strong>with</strong> an intermediary.Consider having supervisory authorities provide guidance as to how to implementthe provision to monitor customers’ activities.Introduce a broader requirement to pay special attention to business relationshipsand transactions <strong>with</strong> persons from countries which do not or insufficiently applythe FATF recommendations.Assess effectiveness of the reporting regime to check for potential under-reporting.Address the misalignment between the criminalization standard and the reportingrequirement., either through legislative changes or enhanced supervision to guardagainst potential under-reporting.Adopt measures that bring the reporting regime in the Faroe Islands and Greenlandup to international standards, especially in the area of terrorist financing.Enhance outreach to insurers and investment agents.Increase compliance <strong>with</strong> the system, including through use of sanctions and fines