Within our AFC function, the AML unit is responsible for instituting measures to prevent money laundering and combat the financing of terrorism, including measures to
- comply with rules and regulations regarding identification (authentication), recording, and archiving;
- detect suspicious transactions and process suspicious activity alerts; and
- develop, update, and execute internal policies, procedures, and controls.
Irrespective of the value or amount, if there is a reasonable suspicion that funds have been derived from illegal origins or may be used in the context of terrorism financing, the transaction must be declined.
The AML unit is designed to comply with German rules as a minimum, as well as local laws and regulations in all countries the bank operates in. It includes policies, procedures, a designated Money Laundering Officer, independent controls, and regular employee training. The percentage of overdue AML trainings is 0.08% (excl. Postbank).
We are part of the Wolfsberg Group of Banks and have adopted the Wolfsberg Anti-Money Laundering Principles, as well as signing the Wolfsberg Statement on the Suppression of the Financing of Terrorism.
Despite our efforts to prevent money laundering there have been instances in which the bank agreed to pay civil monetary penalties to settle investigations into the bank’s AML control function as further described in our Annual Report 2017, Notes to the Consolidated Balance Sheet, Note 29 – Provisions – Current Individual Proceedings – Russia/UK Equities Trading Investigation.