Project AML/TEK is the result of this assignment. The project analyses seven initiatives with the goal of facilitating a more efficient use of technology, thereby strengthening the first line of defence, particularly through an increased use of the existing digital infrastructure in Denmark. The initiatives touches on various areas, as for example broader use of electronic identity solutions, the establishment of a public PEP-solution, and the possibility of allowing banks to share risk flags. Thus, the initiatives generally reflect the highly digitised nature of the Danish society, but are to a varying degree also applicable to other European countries and could serve as an inspiration towards better, more automated processes and a higher harmonisation of KYC procedures in the EU
The report does not present fully developed initiatives, but rather seeks to provide a clear baseline, which can facilitate an informed political decision on the next step of the efforts against ML/TF. A central part of the analysis is therefore a close look at the trade-off between the value of the specific initiatives and the legal implications for the individual or the company, for the customers of the company as well as the legal basis for accessing and potentially sharing the data in question, which are universal questions.
Project AML/TEK is currently subject to a public consultation and the DFSA hope to both further stimulate the discussion on this very important topic and to gain insights into the opinions of all interested parties. The DFSA therefore welcomes all questions, suggestion and opinions, and hope that you can find the time to share them with us.
All input must be sent by email to firstname.lastname@example.org with a copy sent to email@example.com or by mail to the Danish Financial Supervisory Authority, Århusgade 110, 2100 København Ø, Att.: Lars Navntoft Henningsen.