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Deutsche Bank Fined £163 Million for Serious AML Control Failings
7th February 2017
Deutsche Bank receive record AML Fine
Last week the FCA fined Deutsche Bank AG £163,076,224 for failing to maintain adequate anti-money laundering (AML) controls during January 2012 to December 2015.
This is the biggest fine the FCA (or its predecessor the FSA) has ever imposed for AML control failings.
The biggest failings were that Deutsche Bank failed to properly oversee the formation of new customer relationships and the booking of global business in the UK.
As a result of Deutsche Bank’s inadequate AML controls, the Bank was used by “unidentified customers to transfer approximately $10 billion, of unknown origin, from Russia to offshore bank accounts in a manner that is highly suggestive of financial crime”.
Amongst the significant AML control deficiencies found by the FCA at Deutsche Bank were that they:
Consequently, Deutsche Bank failed in being able to obtain sufficient information about its customers to adequately perform a risk assessment and provide a basis for transaction monitoring.
The Director of Enforcement and Market Oversight at the FCA, Mark Steward, said:
“The size of the fine reflects the seriousness of Deutsche Bank’s failings. We have repeatedly told firms how to comply with our AML requirements and the failings of Deutsche Bank are simply unacceptable. Other firms should take notice of today’s fine and look again at their own AML procedures to ensure they do not face similar action.”
The regulator is continually emphasizing the importance of having a robust AML control framework and firms are frequently reminded of how to comply with AML requirements and of the importance of safeguarding the UK financial system from financial crime.
Had Deutsche Bank not agreed to settle at an early stage of the FCA’s investigation the financial penalty would have been £229,076,224.
If you would like assistance in reviewing your current client due diligence processes or client-on-boarding procedures or if you would like to arrange tailored AML training for your firm, please contact our experienced team of compliance specialists who would be happy to help.
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- AML & Prevention of Financial Crime,
- Role of the MLRO
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Comment from the FCA:
“Financial crime is a risk to the UK financial system. Deutsche Bank was obliged to establish and maintain an effective AML control framework. By failing to do so, Deutsche Bank put itself at risk of being used to facilitate financial crime and exposed the UK to the risk of financial crime.”
Mark Steward, FCA Enforcement and Market Oversight, January 2017
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