Anti-Money Laundering initiatives at Soren

We protect our clients and promote social responsibility

SOREN HOLDING ApS takes its duty towards social responsibility very seriously and upholds the Danish Bankers Association’s code of conduct to combat financial crime.

We put ethics above profit

We do not accept clients that do not live up to our standards regardless of earnings. We aim to go beyond simply complying with the letter of the law. Our policies, processes and practices reflect the spirit and intent of the law as well.

Our company culture keeps us focused

Preventing money laundering and terrorist financing is embedded in the way SOREN HOLDING ApS operates, through our culture, education and communication. We encourage all employees to take individual and collective responsibility against financial crime. We take into account non-financial considerations when we employ, promote, and remunerate.

Management is actively involved

Management sets the tone from the top with clear expectations that filter through the entire organisation. Compliance with rules and regulations, including against financial crime and terrorist financing, is anchored in the foundation of the company’s strategy execution plan and defined by specifically outlined objectives and priorities.

We collaborate with all stakeholders, including the authorities

We work constructively with our partners (correspondent banks and liquidity providers) to counter money laundering and financial crime. We report suspicious activity to the authorities and we work collaboratively with the relevant authorities. We are transparent in our measures to counter financial crime and terrorist financing.

SOREN HOLDING ApS’s AML policy

SOREN HOLDING ApS is committed to high standards within financial crime compliance. It is a priority throughout the company to stay focused on the risks, prevent regulation breaches and avoid facilitating clients or transactions involved in financial crime.

The Board of Directors sets fundamental financial crime standards across SOREN HOLDING ApS in its AML Policy and Risk Appetite Statement.

Soren’s organisational setup covers three lines of defence

To be confident that SOREN HOLDING ApS complies with AML regulations, the company adheres to the three lines of defence governance model.

The three lines of defence model ensures effective risk management and creates a clear division of responsibilities between the different functions within the company.

First line of defence

The company’s business units have the primary responsibility for establishing, complying with and enforcing measures to reduce the company’s risk of money laundering and terrorist financing.

Second line of defence

The compliance functions control and assess the adequacy and effectiveness of the measures and procedures put in place to comply with rules and regulations, as well as the actions taken to address any deficiencies in SOREN HOLDING ApS’s compliance.

Third line of defence

Independently, Internal Audit evaluates whether the measures are adequate and that they work as intended.

Findings and recommendations from Compliance and Internal Audit must be prioritised and handled within a reasonable timeframe.

Monitoring of clients’ unusual behaviour and transactions

When we onboard clients, we are required to ask questions and collect documentation before opening their account in accordance with KYC policies (Know Your Client). From this, we can build an accurate picture of our client’s identity and understand how they intend to use our services. This is an important aspect in combatting financial crime which is in the clients’, society’s and SOREN HOLDING ApS’s best interest.

We ask a wide range of questions, covering employment, salary and the clients’ source of wealth. We are also required to update and confirm our information on an ongoing basis. The more we know about our clients and their usual behaviour, the faster we can react if something looks odd or wrong.

Soren has also implemented a monitoring system, which detects unusual or suspicious transactions. All generated alerts are investigated and if the suspicion cannot be dismissed, the client is reported to the FIU following regulatory requirements.

Clients and transactions are screened against relevant lists such as sanctions lists.

Employee training

All relevant employees must on an annual basis participate in different training programmes, including completing our AML training. The employee must pass a test to complete the course.

Anti-bribery and corruption

It is a priority for SOREN HOLDING ApS to exercise all due efforts to ensure that corruption does not occur in its business activities. SOREN HOLDING ApS’s commitment to fair dealing is embedded in its Anti-Bribery and Corruption Policy. Upholding high standards of openness, integrity and accountability, the Board of Directors ensures a zero-tolerance approach to corruption.

All employees, including business partners and intermediaries (including White Label Clients, Introducing Brokers, and Referring Agents), have a responsibility to avoid any involvement in corrupt practices.

The Anti-Bribery and Corruption Policy emphasizes individual responsibility. Individuals are prohibited from directly or indirectly offering or accepting benefits or rewards for engaging in improper activities to gain an advantage. All employees also have a responsibility to report concerns or suspicion of bribery and corruption to local Compliance teams. All employees receive anti-bribery and corruption training.

To monitor effectiveness, SOREN HOLDING ApS has a dedicated Anti-Bribery and Corruption team within Compliance who assesses relevant procedures periodically through risk-based monitoring.