Report on Anti-Money Laundering Inspection of Resurs Bank, Branch of Resurs Bank AB, Sweden

Inspection Report 17-06-2026

The Danish Financial Supervisory Authority conducted an inspection at Resurs Bank, branch of Resurs Bank AB, Sweden (the Branch), in January 2026. The inspection was an investigation into the anti-money laundering area. The inspection covered the following areas:

· The Branch's risk assessment regarding money laundering and terrorist financing

· The Branch's organization in the anti-money laundering area

· The Branch's policies, business processes, and internal controls in accordance with the Money Laundering Act

· The Branch's customer due diligence

· The Branch's monitoring of customers as well as investigations of alerts and notification to the Financial Supervisory Authority.

The Danish branch is a branch of a Swedish-based bank, Resurs Bank AB. The bank's business model is primarily consumer-oriented, where the bank conducts banking business in the Nordic countries through branches in Denmark, Finland, and Norway. The bank is organized as one common Nordic organization with vertical business areas and departments, all covering all geographical locations.

The branch in Denmark currently offers unsecured consumer loans, classic credit cards for individuals, as well as unsecured loans and credit intermediated by retailers for financing purchases from the retailer (retail finance). Of the group's total loans, the branch's loans in Denmark account for 13 percent.

Based on the inspection, a number of areas have given rise to supervisory reactions.

The Branch has, in a number of cases, not sufficiently included all relevant risk parameters in its risk assessment of its customers.

If the Branch does not risk-assess its customers based on relevant risk parameters, there is a risk that customers will not be risk-classified correctly. This may result in the Branch not carrying out the necessary customer due diligence procedures and sufficient monitoring for these customers. It is therefore essential that the Branch includes all relevant risk factors regarding the customers, including connection to foreign countries, as well as the purpose, scope, frequency, and duration of the business relationship, in the assessment of the customer's risk of money laundering and terrorist financing.

The Branch has therefore been ordered to conduct a sufficient risk assessment of its customer relationships. In the risk assessment, the Branch must include information about the purpose, scope, frequency, and duration of the business relationship, as well as the factors set out in Annex 2 and 3 of the Money Laundering Act [1].

The Branch has, in a number of cases, not obtained sufficient information about the intended nature of the customer relationship.

There is hereby a risk that the Branch does not know its customers sufficiently well, including that it does not obtain the necessary basis to assess whether the business relationship has a legitimate purpose, including gaining deeper insight into the overall risk profile of the business relationship. This is essential because obtaining information about the intended nature of the business relationship is necessary to conduct sufficient ongoing monitoring of established business relationships, including identifying unusual transactions and activities.

The Branch has therefore been ordered to assess and, where relevant, obtain information about the purpose and intended nature of the business relationship [2].

The Branch has not sufficiently carried out enhanced customer due diligence procedures in relation to high-risk customers.

There is hereby a risk that the Branch does not have the necessary customer due diligence to detect suspicious circumstances and cannot conduct effective monitoring of customers. This is essential because high-risk customers are precisely associated with an increased risk of money laundering or terrorist financing.

The Branch has therefore been ordered to carry out the necessary enhanced customer due diligence procedures regarding those customer relationships where the Branch assesses that there is an increased risk of money laundering or terrorist financing [3].

The Branch does not sufficiently investigate and assess where the customers' funds or payments from others than the customer originate, including whether it is necessary to obtain documentation thereof. Furthermore, the Branch does not sufficiently record its investigations and conclusions. The Danish Financial Supervisory Authority also assesses that the Branch does not sufficiently address inadequate responses from customers.

There is hereby a risk that the Branch overlooks relevant information and circumstances regarding the customer. The Branch must ensure in a sufficient manner that this information is recorded, both because the information may be relevant at the specific time and because it may later become useful and significant information if the Branch must notify the Financial Supervisory Authority of suspicious activity or transactions.

The Branch's investigations must also include information about the origin of the customers' funds if the Branch assesses that this is relevant to the specific case and alert handling. This is essential, as a lack of knowledge and control of the origin of the customers' funds may result in the Branch not detecting that the funds may originate from illegal activities.

The Branch had a very long total case handling time for the Branch's alerts for a significant part of 2025, and a very large proportion of alerts remained open for a long time before being opened by a case handler. The Danish Financial Supervisory Authority notes at the same time that the Branch's new processes have significantly reduced the total case handling time, but that there is still a large proportion of alerts where the case handling is not initiated within a reasonable time.

There is hereby a risk that the Branch does not notify the Financial Supervisory Authority immediately. This is essential, as the police's opportunity to initiate any investigation depends, among other things, on the immediate receipt of information about suspicious transactions and activities.

The Branch has therefore finally been ordered to investigate all unusual transactions and activities that do not have an obvious economic or legal purpose. The Branch must, if relevant, investigate the origin of the customers' funds. The Branch must also ensure that the investigations and conclusions are sufficiently recorded and stored [4]. Additionally, the Branch is ordered to ensure that it timely investigates the background and purpose of unusual transactions and activities [5].

[1] Section 11, subsection 3 of the Money Laundering Act.

[2] Section 11, subsection 1, no. 4 of the Money Laundering Act.

[3] Section 17, subsection 1 of the Money Laundering Act.

[4] Section 25, subsection 1 of the Money Laundering Act.

[5] Section 26, subsection 1 of the Money Laundering Act.

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