Discover career opportunities in Anti-Financial Crime (AFC)

What is money laundering?

Money laundering is the act of creating a legitimate appearance for proceeds gained from criminal activities and thereby concealing these activities. To this end, criminals often move money across national borders and continents. According to the United Nations, each year criminals launder roughly 2 trillion US dollars, approximately 5% of global Gross Domestic Product (GDP).

At Deutsche Bank, we have a responsibility to work together against this kind of abuse of the financial system. Financial crime has the serious potential to ruin lives. It disrupts societies, undermines the integrity of the financial system, and destabilises global security.

An example of where money laundering frequently found is modern slavery and human trafficking:
Every year, an estimated 20.1 million people around the world are forced into labour and debt bondage. Approximately 4.8 million people annually are sexually exploited, with an estimated one in four victims being a child.

Criminals engaged in these activities need to make the proceeds of their activities appear legitimate, often through money laundering. As criminals employ very elaborate and sophisticated schemes that often include the use of banks to “launder” their revenues, a heightened awareness to prevent and detect acts of money laundering is of utmost importance to us all at Deutsche Bank.

What are sanctions and embargoes?

Sanctions and embargoes are restrictive measures agreed and implemented by international bodies, supranational organisations, or national authorities to inhibit certain activities. They can be imposed against or on specific countries, organisations, groups, entities, individuals, vessels, aircrafts, goods or equipment, such as weapons of mass destruction and arms.

Both terms are often used synonymously. However, “sanctions” tend to broadly describe measures or restrictions that may target individuals, entities, businesses and / or countries. “Embargoes”, on the other hand, tend to describe authoritative measures imposed on a state or country to restrict foreign trade.

An important type of risk that sanctions and embargoes address is proliferation financing.
Proliferation financing denotes the provision of funds or financial services used to acquire weapons of mass destruction. These include chemical, biological, radiological and nuclear weapons as well as their delivery systems. It also entails financing transactions to support sanctioned industries of state proliferators that are known to provide revenue streams to fund nuclear weapon programmes.

Another example where sanctions and embargoes can be imposed is the financing of terrorism. Terrorists, for example, need money for training, recruitment, and the support of other criminal organisations. To prevent and combat terrorism and terrorist financing, most countries have implemented measures such as sanctions and embargoes.

Depending on your role in the bank, you may be more or less exposed to dealings, business or counterparties that could be subject to sanctions. It is important that you are able to identify applicable sanctions risks and escalate concerns to the relevant stakeholders to ensure that appropriate action can be taken.

What is Fraud?

Fraud is the act of intentionally deceiving or misleading others to gain a personal or business advantage. Both individuals and organisations can commit fraud. Fraud is a crime that impacts the health and wealth of every victim. To protect our bank and our clients, we must be vigilant and know how to identify signs of fraud.

Benefits obtained as a result of fraudulent activity are not always purely financial: They may be an invitation to a prestigious event, a new role in a higher position or some other form of increased power or influence.

What is aiding and abetting tax evasion?

The offence of aiding and abetting tax evasion can be dishonestly assisting someone to evade tax, failing to act when legally obliged to do so or being wilfully blind to potential tax evasion. Both individuals and corporate entities alike can be guilty of tax evasion or be complicit in its facilitation.

Every employee in the bank is obliged to follow the bank’s guidelines on the prevention of aiding and abetting tax evasion, no matter where he / she works and whether there are specific laws on tax evasion in his / her jurisdiction.

What are bribery and corruption?

Bribery is the offering of an incentive to persuade another person to do something improper for you, or to offer you something in return. Bribes are not always in cash. Anything of value can be used as a bribe – for example gifts, jobs or insider information.

Corruption is ‘trading in influence’. It involves the abuse of a position to commit a crime. Do not engage in bribery or corruption – these are criminal offences.

What are cybercrime and cryptocurrencies?

In recent decades, financial crime has increasingly expanded into the digital sphere. As a result, cybercrime and the use of cryptocurrencies in illicit activities has grown and banks need to find ways to prevent, detect and address such illegal activities.

Cybercrime denotes the use of a computer for illegal ends and may harm someone’s security and / or financial health. It can be an extension of previously existing criminal activities into a new sphere and has also given rise to new kinds of criminal activity entirely. Due to increasing interconnectivity, the widespread adoption of technology, as well as the transition to fully digital platforms in the cloud, cybercrime has turned into the world’s leading sources of illicit revenue.

Cryptocurrencies and other virtual assets are not only increasingly widespread alternative means of payment, but also more frequently used by criminals. The Blockchain technology, on which the majority of cryptocurrencies operate, permits swift, global and largely anonymous financial transfers in a realm that is less regulated and where identities are difficult to verify, thus providing ways to defy the KYC-principle. Criminals might use cryptocurrencies, for example, to launder money, to receive virtually untraceable payments for ransom or illicit services, or to engage in financial speculation.

Financial institutions that will be active in cryptocurrency markets have the opportunity to play a crucial role in improving transparency and implementing controls to combat financial crimes in a Blockchain-based environment marked by decentralisation and anonymity.

As people and processes – rather than technology – consistently prove to be the weak links in cybersecurity, awareness is needed to mitigate cyber risks and combat cyber-enabled financial crime.

What is Transaction Monitoring and Screening?

Transaction Monitoring and Screening within Anti Financial Crime consists of two main second level controls monitoring on one side the customer transactions of Deutsche Bank and on the other side the client portfolio.
 
The purpose of transaction monitoring (TM) within Anti Financial Crime is to monitor and investigate unusual customer transactions and behavior to identify potential Financial Crime. The TM department will determine if activity identified by the Monitoring Systems (utilizing statistical models),  are considered suspicious and decide if a Suspicious Activity Report (SAR) needs to be filed with regulatory authorities in line with the required rules and regulation. Further the TM department will support the Business in the decision to take further action towards a client for which a SAR was filled (e.g. customer exit).

Name List Screening (NLS) Global aims to identify known high-risk or prohibited relationships within the Bank’s portfolio of clients, staff and third parties as well as for potential new client relationships.

This is achieved through daily screening of these parties against external lists provided via official sources (such as World Check / Dow Jones), internal lists (parties outside of the Bank’s Risk Appetite) and Adverse Media. Screening is performed against four key contexts which are Sanctions and Embargoes, Politically Exposed Persons, Adverse Media and Internal lists.
 
Therefore an effective Transaction Monitoring and Screening environment:

• Provides law enforcement with proactive timely and actionable information on suspicions customer transaction;
• Gives critical information and intelligence to business and AFC management to determine whether further action is required, on transactions or customer relations, such as  exit;
• Allows DB to better manage its risk appetite around higher risk customers, geographies, and products utilizing a risk typology assessment
• Develops and implements globally standardized risk-based approaches towards transaction monitoring and screening, which covers policies, risk analysis, monitoring & screening models and their corresponding monitoring & screening systems, alert handling frameworks, process controls and management information