Trust Updates Archive

20050808BSA Deutsche Bank's Anti-Moneylaundering Policies Deficient, Feds Find

(Oct. 14, 2005--Chicago, IL)--Deutsche Bank Trust Company Americas today entered into a formal agreement with the Federal Reserve to shore up "deficiencies relating to its compliance with federal and state" anti-moneylaundering laws and regulations.
Deutsche Bank Trust Company Americas (DBTCA) is the U.S. commercial banking unit of Germany's Deutsche Bank. While DBTCA has some $100 billion in total fiduciary assets, "the formal agreement addresses only activities on the commercial side," according to a Federal Reserve spokesman.
According to the agreement, DBTCA conducts a high volume of U.S. dollar funds transfer clearing for its respondent banks. Federal Reserve examiners identified compliance and risk management weaknesses in this area.
"We intend to strengthen monitoring systems and business procedures to ensure compliance with recordkeeping and reporting requirements," a bank spokesman told TRN.
DBTCA has agreed to institute procedures to comply with the New York Clearing House Association's "Guidance for Counter Money Laundering Policies and Procedures in Correspondent Banking" (March 2002) and the Basel Committee on Banking Supervision's "Customer Due Diligence for Banks" (October 2001).
The bank stressed that in the agreement with the Fed there were no findings of fraud or moneylaundering and no civil penalties are being assessed.
Reports released in 2001 by the Senate Permanent Subcommittee on Investigations highlighted how correspondent-banking and private-banking services offered by U.S. banks can contribute to international moneylaundering by impeding financial transparency and hiding foreign client identity and activity.
The committee's reports emphasize that banks, including trust banks, are in a difficult position of not always being able to determine the "true" beneficiaries of such accounts.

No statement in this issue is offered as or should be
construed as legal opinion or advice

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