As a responsible bank, we view how we conduct our business as at least as important as our financial performance. We have a long history of supporting regulations and procedures at international level to combat financial crime, and we consider this as vital to ensuring the stability of banks and the integrity of the international financial system as a whole. This helps to protect the bank from being misused for committing criminal offences. Besides that, ignoring financial crime provisions potentially exposes us to corporate criminal and/or regulatory liability, civil lawsuits, and a loss of reputation.
Anti-Financial Crime (AFC) policies are at least reviewed annually to ensure that new regulation is properly reflected in the policies.
Ultimate responsibility for AFC lies with our Management Board, while our AFC division is tasked with the day-to-day prevention of money laundering and terrorism financing, adhering to sanctions’ and embargoes for regimes, and preventing fraud, bribery, and corruption or any other criminal activity. A key objective in 2017 was to strengthen the AFC division therefore, the department increased the number of staff by 60% during the year (excl. Postbank).
The AFC organization is subdivided into Regional, Global, and Central Functions. Their main responsibility is described as follows:
- Regional Functions take responsibility for the regions Deutsche Bank is operating in (Germany, Americas, UK and Ireland, Asia Pacific [APAC], and Europe, Middle East, and Africa [EMEA]).
- Global Functions manage Anti-Money Laundering (AML) / terrorism financing, sanctions & embargoes and anti-fraud, bribery and corruption.
- Central Functions manage topics like risk & controls, investigations, as well as regulatory governance & enforcement
Without prejudice to the Management Board’s oversight duty and the delegation of the above-mentioned tasks to the AFC organization, ultimate accountability for the appropriate structuring and execution of transactions / business activities and their corresponding processes lies with the line managers and employees in the respective business divisions.
Every employee must carefully familiarize themselves and keep up to date with applicable policies and regulations to comply with them.