Bloomberg Law Analysis

ANALYSIS: Don’t Be That Guy’s Bank: Deutsche Bank’s $150M Lesson

July 28, 2020, 6:26 PM

The latest in a series of high-profile anti-money laundering/combating the financing of terrorism (AML/CFT) enforcement actions against Deutsche Bank is a $150 million penalty assessed by the New York Department of Financial Services (DFS), announced July 7. Citing a household name in criminal behavior—Jeffrey Epstein—and two foreign banks best known to AML/CFT specialists—Danske Bank and FBME Bank—this enforcement action should send a warning to all financial institutions of the potential consequences of taking on clients without appropriate risk-based customer due diligence (CDD) and transaction monitoring and suspicious activity report (SAR) filing.

Jeffrey Epstein in the July 7 Enforcement...

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