11 Sep 2020
The U.S. Department of Treasury announced on Wednesday that the largest German investment and financial services provider Deutsche Bank has agreed to pay two settlements totaling US$583,100 for facilitating transactions that violated Ukraine-related sanctions.
According to the department’s Office of Foreign Assets Control (OFAC) enforcement release, Deutsche Bank would pay two settlements of $157,500 and $425,600 for each infraction, which some have argued is a negligible amount for a financial institution that has an annual revenue in the tens of billions.
The first settlement, according to the release, was accepted for the $28,849,038.39 in funds that the bank processed through the United States in August of 2015 on behalf of a Cypriot oil company that had recently been designated as an entity that was linked to an individual who was “contributing to the situation in Ukraine.”
The release explained that at the time Deutsche Bank processed the transaction for the oil company, it “had reason to know” of this designation, given that it “closely coincided” with the date in which it was listed.
The second and larger settlement was due to its processing of 61 payments in December of 2014 to Krayinvestbank, a Russian financial institution that had been designated for its role in the annexation of the Crimea region of Ukraine.
As part of the settlement, Deutsche Bank “agreed to maintain robust compliance procedures by ensuring that its management team is committed to compliance,” the release said.
It also explained that one of the mitigating factors for calculating the total settlement was that the bank “does not appear to have acted with willful intent to violate U.S. sanctions law or with a reckless disregard for its U.S. sanctions obligations” and that no senior staff appeared to be aware of the conduct that led to the recorded violations.
By Eli Moskowitz, OCCRP, 10 September 2020
Read more at OCCRP
RiskScreen: Eliminating Financial Crime with Smart Technology
Advance your CPD minutes for this content, by signing up and using the CPD WalletFREE CPD Wallet