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ANALYSIS: Management Commitment to AML in the Deutsche Bank Case

Aug. 12, 2020, 5:31 PM

The recent $150 million New York Department of Financial Services (DFS) enforcement action against Deutsche Bank was noteworthy for involving Jeffrey Epstein, the infamous sex offender, and Danske Bank, the center of a massive money laundering scandal since 2017. These two sides of the Deutsche Bank case were substantially different from each other, but they shared a common issue: senior management commitment to anti-money laundering (AML) compliance.

Management decisions, not lack of regulatory compliance expertise or resources, were the cause of the AML compliance failures.

The New York DFS’s Consent Order and press release cited remarkably few findings...

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