From at least 1999 through 2006, Deutsche Bank used "non-transparent methods and practices" to conduct more than 27,200 U.S. dollar clearing transactions valued at over $10.86 billion on behalf of Iranian, Libyan, Syrian, Burmese, and Sudanese financial institutions and other entities subject to U.S. economic sanctions.
According to the DFS, in order to facilitate what it saw as “lucrative” U.S. dollar business for sanctioned customers, Bank employees developed and employed several processes to handle dollar payments in non-transparent ways that circumvented the controls designed to detect potentially-problematic payments.
Although several of the employees who were centrally involved in the misconduct no longer work at the Bank, Deutsche Bank will take action to terminate an additional six employees involved in the scheme who currently remain employed; and ban three other employees from any duties involving the firm’s U.S. operations.
Acting Superintendent Anthony Albanese said:
“We are committed to investigating and pursuing sanctions violations and money laundering at financial institutions. We are pleased that Deutsche Bank worked with us to resolve this matter and take action against individual employees who engaged in misconduct. To truly deter future wrongdoing, it is important to focus not just on corporate accountability, but also individual accountability.”