Compliance Lessons From the Federal Reserve’s $186‑Million Fine Against Recidivist Deutsche Bank

Deutsche Bank and its U.S. affiliates resolved two enforcement actions with the Federal Reserve Board, involving fines over “unsafe and unsound” banking practices and violations of earlier consent orders on sanctions compliance and anti-money laundering controls. According to the Fed, Deutsche Bank “made insufficient remedial progress” and “had deficient anti-money laundering internal controls.” Deutsche Bank also agreed to address “other general deficiencies relating to Deutsche Bank's governance, risk management, and controls.” To ascertain the implications for other companies and their boards, the Anti-Corruption Report obtained insights from Hughes Hubbard & Reed partner Michael DeBernardis and Withersworldwide lawyer Martin Auerbach. See “How to Leverage AML Tools for ABC Programs” (May 1, 2019).

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