Financial Crime World

Here is the converted article in Markdown format:

Deutsche Bank Enhances Risk Management and Governance Procedures

In its efforts to strengthen risk management and governance, Deutsche Bank made significant enhancements to its 3 Lines of Defense (3LoD) program in 2015.

3 Lines of Defense Program

The bank’s 3LoD program aims to provide independent and objective assurance regarding the efficiency of risk management, internal controls, and governance procedures. To achieve this goal, Deutsche Bank:

  • Reinforced non-financial risk management and control in the first LoD by:
    • Further building out Divisional Control Units
    • Strengthening and accelerating control enhancements
    • Improving risk and control management procedures
  • Rearranged independent control responsibilities under four Board-level positions:
    • Chief Risk Officer (Operational Risk Management)
    • Chief Regulatory Officer (Compliance, Anti-Financial Crime, and G&RA)
    • Chief Administrative Officer (Legal, HR)
    • Chief Finance Officer (Finance, Tax)
  • Reinforced group-wide control frameworks across:
    • Embargoes & Sanctions
    • Anti-Bribery and Corruption
    • Anti-Money Laundering
    • Anti-Fraud functions

Employee Awareness and Training

Deutsche Bank prioritized employee awareness and training in 2015. The bank:

  • Delivered over 47,000 trainings on combating financial crime
  • Provided over 2,500 employees with training on whistleblowing policies
  • Had more than 12,000 employees complete an online Anti-Bribery and Corruption (ABC) course

The bank’s whistleblowing hotline is available to all employees to report concerns or violations of Deutsche Bank policies or codes, laws, rules, and regulations. All reports are investigated independently, and the bank prohibits retaliation against employees who raise concerns in good faith.

Combating Money Laundering and Terrorism Financing

Deutsche Bank has a robust Anti-Money Laundering (AML) program aimed at complying with German AML rules as a minimum and local laws, regulations, and guidance regarding the prevention of money laundering and terrorism financing. The bank’s AML program includes:

  • Employee training and awareness initiatives to ensure that all employees are equipped to identify and report suspicious transactions

GRI Indicators/Standards

Deutsche Bank’s efforts in enhancing risk management and governance procedures align with several GRI indicators and standards, including:

  1. G4-58: Report the internal and external mechanisms for reporting concerns about unethical or unlawful behavior, and matters related to organizational integrity.
  2. G4-SO3: Total number and percentage of operations assessed for risks related to corruption and the significant risks identified.
  3. G4-SO4: Communication and training on anti-corruption policies and procedures.

Conclusion

Deutsche Bank’s efforts in enhancing risk management and governance procedures demonstrate its commitment to maintaining a robust and transparent risk management framework. The bank’s focus on employee awareness and training, as well as its AML program, further underscore its dedication to ensuring the integrity of its operations.