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The Federal Reserve Board on Wednesday announced two enforcement actions against Deutsche Bank AG, its New York branch, and other U.S. affiliates.

First, the Board issued a consent order and a $186 million fine based on unsafe and unsound practices and violations of the Board’s 2015 and 2017 consent orders with Deutsche Bank relating to sanctions compliance and anti-money laundering controls.

The Board found that Deutsche Bank made insufficient remedial progress under the 2015 and 2017 consent orders and had deficient anti-money laundering internal controls and governance processes relating to its prior relationship with the Estonian branch of Danske Bank.

This consent order requires Deutsche Bank to prioritize completion of several critical requirements of the Board’s prior orders.

Separately, the Board announced a Written Agreement to address other general deficiencies relating to Deutsche Bank’s governance, risk management, and controls.

Deutsche Bank issued the following statement in response to the Fed’s actions:

“We are committed to maintaining robust risk management programs with a special emphasis on Anti-Financial-Crime and Compliance controls. The Written Agreement and the Consent Order with the Federal Reserve relate to our historic tardiness in adhering to older enforcement actions and agreements, as well as a correspondent banking relationship we exited in 2015. We appreciate that the Federal Reserve recognizes the progress we have made in recent years in remediating and resolving control weaknesses. We also recognize that these actions reinforce the need to ensure we stand by our commitments and close our remediation obligations in the near future.

As part of this work, we have taken several actions, including extensive enhancements to our client due diligence and transaction monitoring, and significantly invested in controls since 2019 to enhance our effectiveness and increase the size of our global Anti-Financial Crime team by more than 25 percent – to more than 2,000 employees. Given the momentum we have built in the last two years, we believe we are well positioned to meet our regulators’ expectations. The imposed fine is in large part covered by provisions taken in previous quarters, with the remainder being within the bank’s published cost guidance for the second quarter.”


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