Anti-money laundering legislation applying to AP
In its capacity as a Financial undertaking, The Architects’ Pension Fund (AP) 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 fourth 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 AP with anti-money laundering legislation and has the power to impose sanctions if AP fails to comply with the anti-money laundering act.
The Danish anti-money laundering legislation that AP 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 AP. The Board of Directors of AP has stipulated guidelines for the Executive Board on the implementation of anti-money laundering regulations, etc. AP 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
Arkitekternes Pensionskasse is characterized as being a low-risk counterparty within the meaning of the European Anti-Money laundering regulation.
Based on this categorization it is AP´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 AP and private address can be verified.