NYDFS Consent Order: $150M Penalty Terms

CONSENT ORDER — DEUTSCHE BANK / NY DFS New York Department of Financial Services In the Matter of Deutsche Bank AG Date: July 7, 2020 Penalty: $150,000,000 SUMMARY: The New York Department of Financial Services (DFS) entered into a consent order with Deutsche Bank AG imposing a $150 million penalty for significant compliance failures related to the bank's relationships with Jeffrey Epstein, Danske Bank Estonia, and FBME Bank. EPSTEIN-RELATED FINDINGS: - Deutsche Bank maintained a banking relationship with Epstein from 2013 to 2018 - The bank onboarded Epstein as a client despite his 2008 conviction - Internal due diligence identified Epstein as "high risk" but the relationship proceeded - Over the course of the relationship, the bank processed hundreds of transactions - Transactions included payments to individuals who were publicly alleged to be Epstein co-conspirators - Cash withdrawals totaled hundreds of thousands of dollars - Suspicious transactions were not adequately flagged or reported SPECIFIC COMPLIANCE FAILURES: - Inadequate due diligence at client onboarding - Failure to detect and investigate suspicious transactions - Failure to file timely Suspicious Activity Reports (SARs) - Inadequate monitoring of the Epstein-related accounts - Bank personnel raised concerns that were not adequately addressed REMEDIAL MEASURES: Deutsche Bank agreed to: - Pay $150 million penalty - Engage an independent monitor - Remediate compliance deficiencies - Enhance transaction monitoring systems Source: NY Department of Financial Services Available at: https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202007071