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Anti-money laundering legislation applying to
The Architects’ Pension Fund

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 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 2005/60/EC).

  • 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 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).

Certain of the legislative documents are available in an English translation.

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.

Under Danish anti-money laundering legislation, customers are required to produce a passport, driver's licence, etc. AP is exempt from this requirement in its capacity as a labour market pension company, whose customers (policyholders) are customers only by virtue of collective agreements in force in the Danish labour market and the highly restricted policy surrender option(s) applying to AP pension schemes.

Due to the exemption from the identification requirement, AP always requires customers to provide proof of identity when policies are surrendered, but not for new or existing policies, unless on a suspicion of money laundering or terrorist financing.