The New York Department of Financial Services (DFS) enforcement action against Deutsche Bank announced on July 7, known mainly for punishing the bank for serving Jeffrey Epstein, has a second dimension: correspondent banking for high-risk foreign banks, including Danske Bank. This action is the latest in a 15-year-long history of finding this problem in Deutsche Bank’s anti-money laundering/combating the financing of terrorism (AML/CFT) compliance.
The lesson—that money-laundering risks of foreign correspondent banks must be adequately addressed—should already have been apparent. And if it wasn’t, then it is now.
It’s Groundhog Day!
The Consent Order between New York DFS and ...