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 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:
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´s 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.