Deutsche Bank

Corporate Responsibility
Report 2015

Respecting sanctions and embargoes

National authorities, economic blocs like the EU, and multilateral institutions like the UN all have the power to impose restrictive measures against countries, organizations, groups, entities, and individuals who infringe internationally-accepted behaviors and norms. These measures are commonly known as embargoes or sanctions.

We have a responsibility to monitor, evaluate, and, if required, observe laws and binding requirements related to financial and trade sanctions set by the EU, Bundesbank, Germany’s Federal Office for Economic Affairs and Export Control, and other authorities, such as the US Office of Foreign Assets Control (OFAC) and the UK Treasury Department.

Our group-wide Embargo Policy, Special Risk Countries Policy, and a specific policy relating to the Office of Foreign Assets Control help us to assess and reduce client risk as part of our onboarding process and periodically thereafter, as well as risks related to particular transactions, countries, and goods.

The Sanctions and Embargoes department is organized globally, with regional teams in Frankfurt am Main, London, Singapore, and New York. We pay special attention to training and awareness on this topic across Deutsche Bank. In 2015, our employees conducted sanctions-related training and were proactively informed with multiple updates on any changes of the relevant sanctions regulations. Apart from providing updated and comprehensive information on the sanctions related to Crimea and Eastern Ukraine, we reinforced that political negotiations with Iran would not yet allow a weakening of our stringent and long-standing policy towards business with counterparties in this country.