Anti-money laundering legislation applying to
Sampension Livsforsikring A/S
In its capacity as a Financial undertaking, Sampension Livsforsikring A/S (Sampension) is subject to:
- The Danish anti-money laundering act (official name: the “Danish Act on Measures to Prevent Money Laundering and Financing of Terrorism”). The Danish anti-money laundering act is based on the third EU Anti-Money Laundering Directive on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing (DIRECTIVE (EU) 2015/849).
- The Danish FSA monitors the compliance of Sampension with anti-money laundering legislation and has the power to impose sanctions if Sampension fails to comply with the anti-money laundering act.
The Danish FSA monitors the compliance of Sampension with anti-money laundering legislation and has the power to impose sanctions if Sampension fails to comply with the anti-money laundering act.
The Danish anti-money laundering legislation that Sampension is subject to is available on the Danish FSA's website (in Danish).
The responsibility for ensuring that the Insurance administration partnership complies with the anti-money laundering rules rests with Sampension. The Board of Directors of Sampension has stipulated guidelines for the Executive Board on the implementation of anti-money laundering regulations, etc. Sampension is administered by Sampension Administration A/S (subsidiary).
Accordingly, under the guidelines issued by the Board of Directors, the Executive Board of Sampension Administrationsselskab A/S has the compliance responsibility for ensuring that the subsidiary complies with and implements anti-money laundering legislation in the Insurance administration partnership to the extent required. For that purpose, the subsidiary has appointed an anti-money laundering officer and is subject to a number of written in-house guidelines on, among other things:
- training and instruction programmes for the employees
- customer identification (actual information about individuals and companies)
- red flags, duty to investigate and duty of notification to Denmark's Public Prosecutor for Special Economic and International Crime
- duty to store records and to conduct internal controls with a view to ensuring that anti-money laundering requirements are observed
- risk assessment, risk management, management control and communication.
Policy for delivery of identity information
Sampension is characterized as being a low-risk counterparty within the meaning of the European Anti-Money laundery regulation.
Based on this categorization it is Sampension ' policy only to deliver a copy of the relevant persons (defined as being either the CEO, CIO or the Chairman of the Board) passport´s for identification and Know Your Customer purposes.
Copy of utility bills and/or other identification cards will not be distributed for identification and Know Your Customer purposes. Instead we refer to the public and official Danish Central Business Register at: www.cvr.dk. At the business register the relevant person´s role/connection to Sampension and private address can be verified.