Deutsche Bank AG
FCA enforcement action, 2017
What failed
Deficient KYC and a flawed mirror-trading scheme allowed billions to be moved out of Russia through matched trades with no economic purpose.
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The controls that would have caught it
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In short, the firm needed
- KYC and source-of-funds checks proportionate to client risk
- Detection of matched or mirror trades lacking economic rationale
- Front-to-back monitoring across the investment bank
- Independent assurance over high-risk corridors
High-Risk Corridor & Geography Monitoring
DetectiveTransaction Monitoring
Watches payments to and from higher-risk countries and routes, and flags activity that does not fit the customer or looks designed to disguise where money is really going.
- Starting threshold:
- Any payment to/from a high-risk jurisdiction not in the customer's declared geographies; OR cumulative value to high-risk corridors > 2x declared expectation in a rolling 30 days; OR 5+ low-value payments to a single TF-risk geography in a rolling 30 days.
- First-line owner:
- Financial Crime Operations Analyst (transaction monitoring / sanctions-adjacent)
Mirror & Matched-Trade Detection
DetectiveTransaction Monitoring
The firm spots pairs of offsetting trades that move value across borders with no real economic purpose, the classic way of laundering or moving money disguised as trading.
- Starting threshold:
- Flag offsetting buy/sell pairs in the same or fungible instrument where notional matches within 5 percent, the legs execute within 7 days, the accounts are commonly controlled or related, and the legs settle across different jurisdictions or currencies; prioritise where the round-trip nets near-zero P&L.
- First-line owner:
- Trade Surveillance / Financial Crime Investigations team
Typologies behind this case
Related enforcement cases
Next steps
Enforcement data is sourced from the FCA fines dataset. The control mapping is an analyst view of what would have addressed the failings described in the public notice, not a statement of the regulator's findings.