Realkredit Danmark has outsourced the responsibilities
on designing, implementing, operating and maintaining
relevant financial crime processes and controls to
Danske Bank. Throughout 2022, the outsourcing govern-
ance model for financial crime risk management and
controls developed in 2021 turned out to truly support
the high ambitions for maturing the processes and con-
trols required to support compliance with applicable fi-
nancial crime regulation and internal financial crime risk
mitigation standards.
Compliance
Realkredit Danmark keeps focusing on ensuring a robust
compliance culture across its organisation, thereby en-
suring that we live our core value of integrity in all inter-
actions with our customers and stakeholders.
Realkredit Danmark is subject to the Danish Financial
Business Act and other regulation applying for mortgage
credit institutions in Denmark. Managing and controlling
the compliance of this regulation is performed by the
Realkredit Danmark organisation in accordance with a
three lines of defence risk management and control
model, thereby ensuring that compliance is an integral
part of the day-to-day operation of the business at all
levels in Realkredit Danmark.
Treating customers fairly remains a high focus area in
Realkredit Danmark, including GDPR compliance.
Realkredit Danmark has outsourced the statutory data
protection officer role and responsibilities and other
GDPR processes to Danske Bank A/S, but maintains its
own internal experts to support the organisation in
Realkredit Danmark in its day-to-day operation of activi-
ties comprising personal data.
The second line of defence is anchored in Realkredit
Danmark’s Compliance unit. Some of the day-to-day
compliance tasks continue to be outsourced to Danske
Bank A/S, but the overall responsibility for the second
line compliance function lies with the Head of the Com-
pliance unit, who reports directly to the Executive
Board.
Internal control and risk management systems used
in the financial reporting process and Internal Audit
As laid down in the Danish Financial Business Act, the
Board of Directors is responsible for ensuring that the
Executive Board maintains effective procedures to iden-
tify, monitor and report on risks, adequate internal con-
trol procedures as well as satisfactory IT controls and se-
curity measures.
The responsibilities of the first line Business Risk &
Governance unit are continuously to support and provide
advice to the organisation and units in Realkredit Dan-
mark on managing regulatory, legal and non-financial
risks within their areas of activities and responsibilities,
including implementation of policies and other frame-
works applicable to them. During 2022, more resources
have been allocated to the unit to strengthen the risk cul-
ture across Realkredit Danmark and to achieve a solid
coherence between the governance model for Realkredit
Danmark and the management of the inherent risks asso-
ciated with the business activities of the undertaking.
Good accounting practices are based on authorities, seg-
regation of duties, regular reporting requirements and
significant transparency in respect of the Group’s busi-
ness.
Realkredit Danmark regularly assesses risks in relation
to financial reporting, with particular focus on items
where estimates and assessments could significantly af-
fect the value of assets or liabilities. These critical finan-
cial statement items are listed under Significant account-
ing estimates and assessments.
Realkredit Danmark continuously outsources a large part
of the day-to-day operation of its business activities to
Danske Bank to achieve technical and operational bene-
fits. On the risk management side, this involves specific
outsourcing of risk management responsibilities within
the Realkredit Danmark organisation, which are deliv-
ered on the basis of an outsourcing framework and gov-
ernance model adopted by senior management.
Realkredit Danmark has implemented controls to coun-
ter identified financial reporting risks and regularly mon-
itors changes in and compliance with relevant legislation
and other financial reporting rules and regulations. Con-
trols have been established for the purpose of prevent-
ing, detecting and correcting any errors or irregularities
in the financial reporting.
Business Risk & Governance reports directly to the Ex-
ecutive Board and participates in Realkredit Danmark
risk committee and product committee meetings. Fur-
ther, the head of Business Risk & Governance is the des-
ignated anti-money laundering officer as well as the des-
ignated outsourcing officer for Realkredit Danmark.
As previously mentioned, Realkredit Danmark continu-
ously outsources a large part of the day-to-day operation
of its business activities to Danske Bank to achieve tech-
nical and operational benefits. Realkredit Danmark has
established a governance structure to monitor the out-
sourced activities and to ensure a procedure involving
In 2022, Realkredit Danmark retained its strong focus on
financial crime compliance to prevent criminals from
using mortgage loans and properties mortgaged with
loans from Realkredit Danmark for criminal purposes.
Realkredit Danmark Annual Report 2022 21