The tender is for two subcontracts regarding investigation and analysis of transaction monitoring in Danske Bank (subcontract 1) and Nordea Denmark (subcontract 2).
The tenderer is required to submit a solemn declaration regarding impartiality as a part of the tender. The tender shall also contain such declarations signed by any subcontractor to the tenderer, any party to a consortium and any other entities that the tenderer relies on in regard to technical and professional capacity.
The price for each subcontract cannot exceed 4.870.000 DKK incl VAT, all forms of fees and travel expenses.
Through the investigation and analysis the DFSA among other things (see appendix 1 for the full list) wants to determine:
1) Whether the monitoring in each bank are in line with international best practice for banks of similar size and nature;
2) Whether there are matters to consider from a supervisory point of view on the systems concerned and their use by the banks; and
3) Whether there are matters to be aware of from a supervisory point of view when dealing with alarms by banks.
The supplier must use gap analysis and benchmark monitoring against legislation and international best practice to assess whether the transaction monitoring of the bank meets relevant requirements. The investigation and analysis are to result in a written report with documentation to be delivered by the end of 2020.
The supplier shall allow each bank the opportunity to review and comment on the findings of the investigation in a draft final report, such comments to be taken into consideration and reflected in the final report where relevant. Furthermore, the supplier shall, where possible, be transparent towards the bank with the findings during the investigation.
The conclusions of the investigation and analysis must enable the DFSA to determine whether the requirements in applicable law for customer monitoring are complied with for each bank, and whether administrative reactions must be made to the bank concerned. The supplier must therefore comply with relevant requirements of the Danish Public Administration Act in this area.
With regard to Danske Bank, the investigation and analysis must cover all business units and business operations of the bank, including subsidiaries, and including foreign branches and subsidiaries, except Danica, Realkredit Danmark, units abroad that are in liquidation and entities that do not carry out transactions or do not carry out transaction monitoring independently.
Through the investigation and analysis the DFSA among other things (see appendix 1 for the full list) wants to determine:
1) Whether the monitoring in each bank are in line with international best practice for banks of similar size and nature;
2) Whether there are matters to consider from a supervisory point of view on the systems concerned and their use by the banks; and
3) Whether there are matters to be aware of from a supervisory point of view when dealing with alarms by banks.
The supplier must use gap analysis and benchmark monitoring against legislation and international best practice to assess whether the transaction monitoring of the bank meets relevant requirements. The investigation and analysis are to result in a written report with documentation to be delivered by the end of 2020.
The supplier shall allow each bank the opportunity to review and comment on the findings of the investigation in a draft final report, such comments to be taken into consideration and reflected in the final report where relevant. Furthermore, the supplier shall, where possible, be transparent towards the bank with the findings during the investigation.
The conclusions of the investigation and analysis must enable the DFSA to determine whether the requirements in applicable law for customer monitoring are complied with for each bank, and whether administrative reactions must be made to the bank concerned. The supplier must therefore comply with relevant requirements of the Danish Public Administration Act in this area.
With regard to Nordea Denmark, the investigation must only cover the group's bank branch in Denmark.