Compliance
Compliance with legal framework conditions
We regard compliance as an integral part of our corporate culture and expect all our employees to take responsibility and satisfy our compliance principles.
Compliance risk arises when insufficient compliance with laws, rules, and regulations triggers legal or regulatory sanctions against the bank or results in financial or reputational damage.
The compliance and anti-money-laundering program helps Deutsche Bank minimize and manage its compliance risk.Our Global Compliance Core Principles set out requirements for employee behavior.
To be able to perform these tasks effectively, the Compliance Department is independent from the bank’s operative departments. World-wide, close to 680 employees work for this department, with 135 of them responsible for the anti-money-laundering program.
Highly sophisticated filter and monitoring systems are used to scrutinize new clients, existing accounts and current transactions.
Each day about 18,000 new accounts are opened with Deutsche Bank. We have more than 14 million clients world-wide and conduct more than ten million transactions with an aggregated volume of about €1 trillion every day.
Core responsibilities of the compliance department
- Providing advice to the individual business units on applicable laws, directives and regulations and supporting the departments in the implementation of these rules
- Developing and communicating global and local internal compliance principles, standards and procedures
- Monitoring and verifying conformity with compliance standards
- Advising on the lawfulness of transactions, products and services that the bank offers
- Supervising reputational risk management on behalf of the Management Board
- Coordinating risk control with other functions
- Managing daily communications with regulatory agencies around the world
- Supporting compliance with the bank’s internal confidentiality barriers (“Chinese walls”)
- Initiating and implementing measures within the scope of the anti-money-laundering program to ensure compliance with embargo provisions that apply in the EU and in other countries in which the bank maintains subsidiaries and branches
- Implementing advisory and monitoring measures to ensure that occurrences that give reason to suspect money laundering or the financing of terrorism are brought to light and, as required by law, reported to the law enforcement authorities
- Providing employees with regular training and education on the applicable rules and regulations
- Presenting a coordinated response to proposed legislation
Anti-money-laundering measures and programs
Anti-money-laundering measures and programs
With its anti-money-laundering program, the bank lends strong support to international efforts to combat money laundering, the financing of terrorism, and other criminal acts.
We continually review our anti-money laundering strategies and objectives and maintain an efficient anti-money laundering program for our operations. Deutsche Bank is committed to high anti-money-laundering standards and expects its managers and employees to comply with these standards to prevent any abuse of the bank or its products and services for the purposes of money laundering and financing terrorism.
We comply with, among other things, the recommendations of the Financial Action Task Force on Money Laundering (FATF) and the recommendations and standards of the Basel Committee on Banking Supervision. We are a member of the Wolfsberg Group, in which leading internationally operating banks have joined forces to map out principles for combating money laundering and the financing of terrorism. Cross-departmental workgroups implement the Money Laundering Act, which has been amended to bring it in line with the Third EU Money Laundering Directive.
Global anti-corruption program
As part of our global program to prevent corruption, we regularly monitor the risk of corruption and internal control mechanisms are aligned to the provisions in international treaties and local legislation.
A key element of the program is a clearly defined set of rules and regulations, one of these being the Global Anti-Corruption Statement in the Global Compliance Core Principles.
A Group Policy regulates the acceptance and the giving of gifts and invitations. A computer-based system is used to record and monitor gifts and invitations.
A global, professionally run telephone hotline has been introduced in all regions where the bank operates. It provides our employees with another way of addressing issues in good faith, confidentially and without fear of negative repercussions. To accompany these measures, a Web-based, mandatory training “Preventing Corruption & Fraud” has been rolled out to the entire staff globally.