On Jan. 31, 2019, EST FSA issued response to DenFSA comment on responsibility.
- English summary of report contains a number of allegations or positions that the
Financial Supervision Authority does not accept based on the legal circumstances.
- Danske Bank's organization and management didn't work, task of Danish financial supervision was and is to oversee organization and management of Danske Bank.
- In 2014 / 2015, EST FSA forced Danske to close non-resident business in Estonia.
- No other institution in Denmark or Estonia was actively involved in eliminating or weakening these risks at the time in the Bank's organization and management.
- Except for the Estonian Money Laundering Data Bureau, which assisted the FSA.
- Under current European rules, the competent authorities in Estonia and Denmark have shared responsibility for monitoring ML/TF in the Estonian branch of Danske.
- In shared tasks, DenFSA has lead role in overseeing organization / management.
- EST FSA has repeatedly clarified that AMLD3 did not regulate the competence of
institutions for cross-border activity, in respect of the freedom of establishment.
- According to EST FSA, combating ML/TF in bank means building up appropriate
control systems, which are part of Danske Bank's organization and management.
- Artificial to differentiate organization and management for money laundering and terrorist financing risk from the organization and management of the rest of bank.
- Bank's organization and management are one, EU home country supervisors also
deal with money laundering risk control planning in branches in another country.