- Anti-Financial Crime head count increased by 33%
- Measures strengthened to create awareness of bribery and corruption
- Business Intelligence Unit established
We are actively involved in international and local efforts to combat financial crime, including money laundering, the funding of terrorist and criminal activities, fraud, bribery, and corruption, and adhere to all international embargoes and sanction controls.
We have long advocated for stringent global regulations on these issues to ensure the stability of banks and the integrity of the international financial system. Our priority is to protect Deutsche Bank and our clients from criminal abuse and to uphold trust in our business and sector.
How we do it
Confronting financial crime is coordinated by our Anti-Financial Crime (AFC) division, which has a reporting line to our Management Board. Monthly and quarterly reports are made to the responsible Board member, with quarterly reports also submitted to the Supervisory Board informing about AFC structure and governance updates, functional and regional topics. This reporting line also applies to ad hoc reports.
AFC is part of our global Three Lines of Defense (3LoD) program. In 2015, we conducted a gap analysis and developed an internal control framework across all Anti-Money Laundering (AML) risk types, including sanctions and embargoes, Anti-Bribery and Corruption (ABC), and Anti-Fraud and Investigations and other Financial Crime. These have become part of our Non-Financial Risk Taxonomy. We also set a future target operating model for existing risk and control functions to reflect 3LoD principles going forward.
In 2015, our focus was on hiring activities to respond to increased global regulatory demands and on strengthening our control environment accordingly. This included establishing a Business Intelligence Unit to provide research and due diligence on legal, financial, regulatory, or reputational risks presented by “sensitive clients.” We also expanded ABC initiatives and the stringency of our Global Gifts and Entertainment guidance.
Global risk assessments provide a framework to tackle AML, sanctions and embargoes, ABC, and Anti-Fraud and Investigations. Maintaining control over these risks relies on adequate and up-to-date information on client relationships. Our Know Your Customer (KYC) standards, the New Product Approval and New Transaction Approval processes provide a consistent group-wide framework to ensure that all product and transaction developments, including changes to existing products, are reviewed by key control functions, including AFC.
Even with these controls in place, we know we will only make a difference in tackling financial crime by engaging every one of our employees—they form the first, second, and third lines of defense. In 2015, more than 47,000 trainings were delivered on combating financial crime. Over 12,000 employees completed the online ABC course, which covers the extraterritorial application of laws.
Our whistleblowing hotline remains available to all employees to raise concerns or report violations of Deutsche Bank policies or codes, laws, rules, and regulations applicable to Deutsche Bank in complete confidence. All reports are investigated independently, and our policy prohibits retaliation. In 2015, more than 2,500 employees received training in our whistleblowing policies.
To keep pace with the growing sophistication of financial crime, and the dynamic and increasingly cautious regulatory environment, we will continue to expand our expert teams in AFC; review our KYC and onboarding procedures across Deutsche Bank to suspend the onboarding of new clients and the introduction of new products in higher-risk locations; and further invest in our IT systems.