Financial Crime Risk Assessment Template for Denmark

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Financial Crime Risk Assessment

Document background

The Financial Crime Risk Assessment is a crucial regulatory document required for organizations operating under Danish financial regulations and EU directives. It serves as a comprehensive evaluation tool for identifying, assessing, and managing financial crime risks within an organization. This document becomes necessary when organizations need to demonstrate their understanding of financial crime risks to regulators, during periodic risk reviews, or when significant changes occur in business operations or regulatory requirements. The assessment typically includes detailed analysis of customer risks, product risks, geographical risks, and delivery channel risks, along with evaluation of control effectiveness and recommendations for enhancement. Under Danish law, this assessment forms a fundamental component of an organization's anti-money laundering and counter-terrorist financing framework, requiring regular updates and regulatory reporting.

Suggested Sections

1. Executive Summary: Overview of key findings, risk ratings, and major recommendations

2. Introduction and Scope: Purpose of the assessment, scope of review, and methodology used

3. Regulatory Framework: Overview of applicable laws, regulations, and compliance requirements

4. Business Profile Assessment: Analysis of business activities, products, services, and customer base

5. Inherent Risk Assessment: Evaluation of inherent risks across different risk categories including products, customers, geographies, and channels

6. Control Environment Assessment: Review of existing control frameworks, policies, procedures, and systems

7. Residual Risk Assessment: Analysis of remaining risks after considering control effectiveness

8. Gap Analysis: Identification of gaps in current controls and compliance measures

9. Action Plan and Recommendations: Detailed recommendations for addressing identified gaps and enhancing controls

Optional Sections

1. Technology and Systems Review: Detailed assessment of AML/CFT systems and technology infrastructure - include when organization uses specialized compliance software

2. Transaction Monitoring Assessment: In-depth review of transaction monitoring systems and processes - relevant for financial institutions with significant transaction volumes

3. Sanctions Compliance Program: Detailed assessment of sanctions screening processes - particularly important for institutions with international operations

4. Training and Awareness Program Review: Assessment of staff training programs - include for larger organizations with complex training needs

5. Third-Party Risk Assessment: Evaluation of risks associated with third-party relationships - relevant when significant outsourcing exists

6. Branch Network Assessment: Assessment of risks across different branches - include for institutions with multiple locations

Suggested Schedules

1. Risk Assessment Matrices: Detailed risk scoring matrices for different risk categories

2. Control Testing Results: Detailed results of control effectiveness testing

3. Statistical Analysis: Quantitative analysis of transaction patterns, customer profiles, and risk indicators

4. Regulatory Requirements Checklist: Detailed compliance checklist against relevant regulations

5. Interview List and Summaries: List of stakeholders interviewed and key findings

6. Sample Testing Results: Results of sample testing performed during the assessment

7. Risk Register: Detailed register of all identified risks and their ratings

8. Action Plan Timeline: Detailed timeline for implementing recommendations

9. Systems and Controls Map: Mapping of systems and controls against identified risks

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