Case Study: Deutsche Bank Money Laundering Scheme

April 27th, 2017 by Kara in Case Studies

Deutsche Bank Money Laundering

By: Michelle Chan

The Deutsche Bank Money Laundering Scandal

After Russia’s incursion into Crimea, sanctions by the European Union and the U.S. against Russia forced President Putin to declare “offshorization” illegal in an attempt to keep Russian businesses at home and prevent the declining exchange rate of the ruble from damaging the Russian economy. As a result, Russian billionaires resorted to a more discreet way of funneling money offshore via mirror trading whereby a relatively small amount is traded in each transaction.[1] Thus, creating the Deutsche Bank money laundering scandal. This scandal raises questions about the effectiveness of systems and controls implemented to prevent the occurrence of these types of unethical violations.

Key Players

The central players in the Deutsche Bank money laundering scandal, which gained media attention in late 2016 include:

Deutsche Bank AG

Deutsche Bank is a global German banking and financial services company with more than 100,000 employees in over 70 countries and a large presence in Europe, the Americas, and Asia-Pacific. The company is headquartered in the Deutsche Bank Twin Towers in Frankfurt and was the largest foreign exchange dealer in the world with a market share of 21 percent in 2009. The company offers financial products and services for corporate, institutional, private and business clients. Deutsche Bank provides services that include sales, trading, research, origination of debt and equity, mergers and acquisitions (M&A), risk management products, such as derivatives, corporate finance, wealth management and transaction banking. Deutsche Bank’s core business is investment banking representing 50% of equity, 75% of its leverage assets and 50% of its profits.[2] Deutsche Bank Ltd (Russia) was established in 1998. Deutsche Bank Russia offers a full range of banking services including commercial and investment banking services to local and international clients.[3]

U.S. Department of Justice (DOJ)

The United States Department of Justice (DOJ) is a federal executive department of the U.S. government, responsible for the enforcement of the law and administration of justice in the United States, equivalent to the justice or interior ministries of other countries.[4] The Department is headed by the United States Attorney General, who is nominated by the President and confirmed by the Senate and is a member of the Cabinet.[5] The current Attorney General is Jeff Sessions.

New York State Department of Financial Services (DFS)

The New York State Department of Financial Services (DFS) is the department of the New York state government responsible for regulating financial services and products, including those subject to the New York insurance, banking and financial services laws. The department’s mission is to foster the growth of the financial industry in New York and spur economic development through judicious regulation and vigilant supervision. The department aims to achieve its goals by ensuring the continued solvency, safety and prudent conduct of the providers of financial products and services, ensuring fair and equitable fulfilment of the financial obligations of such providers and by protecting users of financial products and services from financially impaired or insolvent providers of such services.[6]

Organized Crime and Corruption Reporting Project (OCCRP)

The Organized Crime and Corruption Reporting Project (OCCRP) is an impartial and non-partisan consortium of investigative centers, media and journalists that operates internationally in Eastern Europe, the Caucasus, Central Asia and Central America. It is the only existing full-time investigative reporting organization that specializes in organized crime and corruption in the world. The organization’s goal is to help people around the world understand ways in which organized crime and corruption resides in their countries and governments.[7] OCCRP’s mission statement says, “Our world is increasingly polarized. The world’s media channels are rife with propaganda, misinformation and simply wrong information. We must all strive to understand how our increasingly complex society works. We must be able to find the truth to make the kinds of decisions we need to. We are committed in our small way to telling the truth the best we can.” (OCCRP, 2007).[8]

Transactions

In a press release published on the 30th of January 2017, the New York State Department of Financial Services (DFS) states it found Deutsche Bank and several of its senior managers responsible of neglecting opportunities to detect, intercept and investigate a long-running mirror-trading scheme facilitated by Deutsche Bank’s Moscow headquarters and involving its New York and London branches.[9] Deutsche Bank employees used a mirror-trading scheme to help wealthy Russians move $10 billion out of that country from 2011 through 2014.

Mirror trading is an automated forex strategy that allows investors to imitate international forex trading behaviours and make trading decisions that are independent of any emotional biases. The system uses a forex brokerage’s trading platform to examine various trading strategies and allows the trader to choose a trading strategy based on various options such as the trader’s investment goals, risk tolerance, investment capital and desired currencies. When originators of the trading strategies execute their trades, these trades are duplicated in the mirror traders’ accounts using automated software that operates uninterrupted for 24 hours a day, 7 days a week.[10]

Specific companies that were clients of the Moscow equities desk operated through the equities desk at Deutsche Bank’s Moscow branch. They issued orders to purchase Russian blue chip stocks. These companies would always pay for the stocks in rubles. Through Deutsche Bank’s London branch, a related counterparty would then sell the identical Russian blue chip stock sometime thereafter in similar quantities and at the same price in US dollars.[11] The counterparties involved were mostly U.K. Limited Partnerships or Limited Liability Partnerships. They were often linked by common beneficial owners, management or agents, with “designated members” registered in tax havens and trade stocks in similar quantities between the Russian company and the offshore company.[12] These trades were regularly approved by the bank’s Deutsche Bank Trust Company of the Americas (DBTCA) unit. The selling counterparties were usually registered in an offshore territory and paid for shares in U.S. dollars. At least 12 entities were involved, and none of the trades demonstrated any legitimate economic rationale.[13]

Mirror trading is unethical because, when done in large quantities, it can be used to facilitate money laundering practices, which is the act of transferring large sums of money obtained from illegitimate and often illegal practices to tax havens around the world. This is usually done to evade any legal repercussions and taxes, which in return, contributes to on-going illegal activities viewed as profitable and without legal consequences. Money laundering practices take place through mirror trading as mirror trades bypass currency controls, anti-money-laundering laws, and, possibly, tax controls when moving money overseas.[14]

The investigation carried out by the New York State Department of Financial Services (DFS) exposed Deutsche Bank for violations that include the following:

  • The bank conducted its banking business in an unsafe and unsound manner, failing to maintain an effective and compliant anti-money laundering program.[15]
  • The bank failed to maintain and make available true and accurate books, accounts and records reflecting all transactions and actions.[16]
  • The Deutsche Bank Trust Company of the Americas (DBTCA) unit was unresponsive to efforts made by outside sources to stop the mirror trading scheme. In addition, the senior compliance employee did not take any steps to investigate the basis for the European Bank’s inquiry.[17]
  • The bank’s Know Your Customer (KYC) processes were weak, functioning merely as a checklist with employees mechanically focused on ensuring documentation was collected. Virtually all of the KYC files for the companies involved in the scheme were insufficient.[18]
  • The bank failed to accurately rate its country and client risks for money laundering throughout the relevant time period and lacked a global policy benchmarking its risk appetite.[19]
  • The bank’s anti-financial crime, anti-money laundering (AML) and compliance units were ineffective and understaffed.[20]

The DFS worked closely with the Financial Conduct Authority of the UK on the investigation to uncover Deutsche Bank’s failure to detect, investigate and stop the mirror trading scheme due to extensive compliance failures.[21] This negligence allowed the scheme to continue for years.

Outcomes

So far, three Deutsche Bank employees have been suspended, two Co-C.E.O.s of the bank have announced their resignation and new Co-C.E.O., John Cryan, has announced the forthcoming closure of all investment-banking activity in Russia.[22] Currently, the bank is under investigation by the U.S. Department of Justice, the New York State Department of Financial Services and financial regulators in the U.K and in Germany for allegations of money laundering in Deutsche Bank’s Moscow office.[23]

On the 30th of January 2016, Financial Services Superintendent Maria T. Vullo announced that Deutsche Bank AG and its New York branch will be required to pay a $425 million fine and hire an independent monitor.[24] This $425 million dollar fine seems a drop in the ocean in comparison to billions of dollars bank employees have profited from the aforementioned unethical practices.[25] As part of a consent order entered into with the New York State Department of Financial Services (DFS) for violations of New York anti-money laundering laws involving a “mirror trading” scheme among the bank’s Moscow, London and New York offices that laundered $10 billion out of Russia, Deutsche Bank must engage an independent monitor within 60 days of the consent order. This independent monitor must be approved by DFS to conduct a comprehensive review of the bank’s existing anti-money laundering (AML) compliance programs, policies and procedures that refer to or affect activities conducted by or through its DBTCA subsidiary and the New York branch.[26]

Furthermore, within 30 days of the selection of the independent monitor, Deutsche Bank, DBTCA and the New York branch must submit to DFS an engagement letter, for DFS’s approval, that provides for the independent monitor to review and report on, among other things:

  • The elements of the bank’s corporate governance that contributed to or facilitated the improper conduct and allowed it to go on for such a long time,
  • Relevant amendments or reforms to corporate governance that the bank has made since the time of the improper conduct and whether those changes or reforms are likely to significantly enhance the bank’s AML compliance programs going forward,
  • The thoroughness and comprehensiveness of the bank’s current global AML compliance programs.[27]

In addition, Deutsche Bank must submit a written action plan to enhance its current global AML compliance programs that pertain to or affect activities conducted by or through DBTCA and the New York Branch.[28]

Ethics Violations

1. Failure in its Duty to Detect, Investigate and Stop Illegal Practices Within the Institution

Deutsche Bank failed in its fiduciary duty to act on the various opportunities to detect, investigate and stop the mirror trading schemes taking place throughout the years by its employees. Deutsche Bank’s failure to uphold its duty compromised the integrity of financial institutions that should provide preventive services and should not, under any circumstances, have allowed for or tolerated illegal practices such as money laundering and fraud to take place without reporting the illegal behaviour. Among the systematic issues present within the bank that have contributed to this scandal are its internal reviewing process and the malpractices of its London and Moscow compliance departments. Elaboration of these points are provided in this section.

A “counterparty” is a new fund intending to trade with Deutsche Bank. In Deutsche Bank’s London and Moscow headquarters, each new fund is subjected to a “double check” by compliance departments to ensure all required documentation is in order. Evidently, all the counterparties wishing to trade with Deutsche Bank passed both internal reviews. Deutsche Bank was also required to complete a “Know Your Client” (KYC) assessment to determine if the client intending to trade is trustworthy by uncovering any taint of criminality the client may have had in its past. However, the KYC processes set in place were weak and Deutsche Bank did not perform a thorough interrogation of the source of funds of its clients.[29] It seems Deutsche Bank was negligent in ensuring any illegitimate funds from their clients were not secretly introduced into the financial system as the KYC procedure put in place at the bank was fixated on the collection of proper documentation and consisted of sales traders requesting counterparties to state the source of their funds without much further questioning on the legitimacy of their claim. Thus, the information provided by potential clients for the companies involved in the KYC files were inadequate to detect an earlier ongoing mirror trading scheme. Moreover, in an article published on the 29th of August 2016, The New Yorker claimed that a Moscow employee who oversaw the illicit mirror trading was also actively participating in the onboarding and KYC documentation of companies involved in the scheme (Caesar, 2016)[30].

Finally, the anti-financial crime, anti-money laundering (AML) and compliance units within Deutsche Bank’s Moscow branch were ineffective and understaffed. Compliance staff had difficulty accessing appropriate resources, leaving existing personnel scrambling to perform multiple roles.[31] The The New Yorker wrote that at one point, an attorney who lacked any compliance background had to serve simultaneously as the Moscow bank branch’s head of compliance, head of legal, and as its AML Officer (Caesar, 2016).[32] This failure was unethical as these processes were put in place to ensure safe, legal transactions and should have been carried out properly, using correct procedures to uphold anti-money laundering, corruption and anti-terrorism funding policies.

The compliance departments in Deutsch Bank’s Moscow and London branches that were supposed to be in charge of ensuring safe and legitimate transactions also failed to perform their intended duty. To illustrate, the companies involved in this scandal were supposedly subjected to a rigorous “client review” process, and all of them were deemed satisfactory by a Deutsche Bank compliance team.[33] But there was a pattern suggesting malfeasance. Clients of the scheme consistently lost small amounts of money. The differences between the Moscow and London prices of a stock were often not in the client’s favour, and clients had to pay Deutsche Bank a commission for every transaction. The commission cost was between ten hundredths and fifteen hundredths of a percentage point per trade.[34] The apparent willingness of counterparties to lose money again and again should have signalled the true purpose of the mirror trades was to facilitate capital flight. However, these signals went by undetected or were wilfully ignored by the compliance department.

The compliance department within Deutsche Bank also failed to effectively tackle allegations of fraud when approached by outside sources. For example, when contacted by a European financial institution about contradictory information on one of the companies involved in the trading scheme, a senior compliance employee who supervised special investigations at the Deutsche Bank Trust Company of the Americas (DBTCA) unit never responded. In addition, the senior compliance employee did not take any steps to investigate the basis for the European Bank’s inquiry, later explaining that the employee had “too many jobs” and “had to deal with many things and had to prioritize”.[35] The neglect and irresponsibility of Deutsche Bank’s compliance department is unethical as it facilitated mirror trading schemes and corruption with a nonchalant attitude towards incidences of money laundering, contributing to this 10-billion-dollar scandal.

2. Institutional Corruption and Conflict of Interest Issues

Banks owe a duty of care to their customers to ensure the transactions carried out on behalf of their clients are legal. However, when the culture of corruption is rife within an institution, conflicts of interest between providing services to benefit a client and abiding by legal regulations arises within the institution. Institutional corruption within the Deutsche Bank Moscow, London and New York headquarters conjured up a host of conflict of interest issues arising from the mirror trading schemes. These schemes go against the fundamental values of anti-money laundering laws and further instill the culture of dishonesty further adding to corruption within the institution.

Many regulators found Deutsche Bank guilty of banking misconduct. In fact, the Financial Conduct Authority of the U.K. sent a letter to Deutsche Bank in March 2016 informing the institution that its London branch had some serious systemic anti-money laundering, terrorist funding and sanctions failings. However, when a lawyer who sat on the bank’s integrity committee was brought in, specifically to improve the controls put in place and analyse any former misconduct, Deutsche Bank executives relieved him of his duties. He apparently had an argument with executives at a board meeting when he attempted to probe the links between senior executives and misconduct at the bank.[36] Hence, it is fair to deduce senior management at the institution failed to act impartially and transparently when faced with institutional corruption and conflict of interest issues that arose from unethical mirror trading schemes.

On the topic of mirror trading schemes, Deutsche Bank has not commented on whose money was expatriated through the mirror trades. The C.E.O., John Cryan, has insisted the bank has not knowingly provided services to Russians on the sanctions list.[37] However, as Deutsche Bank officials did investigate thoroughly the legitimacy of their clients KYC process claims, it is difficult to determine whether the source of funds came from a legitimate law abiding source or otherwise. Moreover, the bank failed to accurately rate its country and client risks for money laundering throughout the relevant time period and lacked a global policy benchmarking its risk appetite.[38] This has resulted in material inconsistencies and no methodology for updating the ratings. Hence, Deutsche Bank was not in line with peer banks, which rated Russia as high risk well before Deutsche Bank did in late 2014. In an interview in March, 2016, Cryan said, “To our knowledge, the individual transaction steps in themselves were innocuous. However, the case raises questions about how effective our systems and controls were, especially with regard to the onboarding of new clients, an area where we experienced difficulties in collecting sufficient information”.[39] This euphemistic language belies the brazen nature of the scheme.

Reports of Deutsche Bank’s internal investigation into mirror trades do not inspire confidence as people struggle to comprehend the level of corruption and unethical behaviour that is rife in the banking industry. Mirror trades that have occurred for at least two years before anyone raised any concerns and were only acted on months after the red flags first appeared depict a bank culture that emphasises employee compliance over sovereign laws. According to Bloomberg News, the internal report notes that, in early 2014, a series of inquiries about the propriety of mirror trades had been logged by multiple parties, including Hellenic Bank, in Cyprus, the Russian Central Bank, and back-office staff members at Deutsche Bank itself. However, when Hellenic Bank executives contacted Deutsche Bank and asked about the unusual trades, they did not hear back from the compliance department. Instead, their inquiry was fielded by the equities desk that was performing the mirror trades. Deutsche Bank’s Moscow branch reassured Hellenic Bank that everything was in order.[40] Deutsche Bank’s failure to maintain an effective money-laundering program and their failure to maintain accurate books, accounts and records reflecting all transactions and actions is not only irresponsible but also dishonest.[41]

Policy Recommendations

As stressed in the DFS’s 30th January 2016 press release, the DFS’s new risk-based anti-terrorism and anti-money laundering regulation, which became effective on January 1, 2017 is significant in regulating financial institutions and preventing similar scandals involving financial institutions from reoccurring. DFS’s regulation requires regulated institutions to maintain programs to monitor and filter transactions for potential AML violations and prevent transactions with sanctioned entities. It also requires regulated institutions to submit an annual board resolution or senior officer compliance finding confirming the steps taken to ascertain compliance with the regulation. In addition, DFS has proposed a first-in-the-nation cybersecurity regulation, effective March 1, 2017, requiring DFS regulated institutions to establish and maintain a cybersecurity program designed to protect consumers and ensure the safety and soundness of New York’s financial services industry.[42] In order to ensure safe and honest transactions, Deutsche Bank officials should consider applying the aforementioned regulations as proposed by the DFS.

Conclusion

Bottom line, based on the information in this case study of the Deutsche Bank money laundering scandal, Deutsche Bank acted unethically because:

  • The institution failed to act impartially and transparently when faced with institutional compliance and legal governance conflict of interest issues arising from mirror trading schemes. These schemes aided corruption and criminal activity because they normalized the act of money laundering in financial institutions.
  • The institution failed in its fiduciary duty to act on the various opportunities to detect, investigate and stop the mirror trading schemes taking place throughout the years by its employees.

 

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NOTES

[1] Caesar, Ed. “Deutsche Bank’S $10-Billion Scandal”. The New Yorker. N.p., 2016. Web. 18 Jan. 2017.

[2] Lee, Peter. “Can Cryan Halt Deutsche Bank’s Decline?”. EuroMoney. N.p., 2016. Web. 18 Jan. 2017.

[3] “Deutsche Bank – History”. Deutsche Bank Russia. Web. 18 Jan. 2017.

[4] “Organization, Mission & Functions Manual: Attorney General, Deputy And Associate, Department Of Justice”. The United States Department of Justice. N.p., 2014. Web. 18 Jan. 2017.

[5] “Organization, Mission & Functions Manual: Attorney General, Deputy And Associate, Department Of Justice”. The United States Department of Justice. N.p., 2014. Web. 18 Jan. 2017.

[6] “NYSDFS: Mission And Leadership”. New York State Department of Financial Services. Web. 18 Jan. 2017.

[7] “About Us”. Organized Crime and Corruption Reporting Project. N.p., 2007. Web. 18 Jan. 2017.

[8] “About Us”. Organized Crime and Corruption Reporting Project. N.p., 2007. Web. 18 Jan. 2017.

[9] New York State Department of Financial Services (DFS),. DFS FINES DEUTSCHE BANK $425 MILLION FOR RUSSIAN MIRROR-TRADING SCHEME. 2017. Web. 25 Jan. 2017.

[10] “Mirror Trading”. Investopedia. Web. 18 Jan. 2017.

[11] Caesar, Ed. “Deutsche Bank’S $10-Billion Scandal”. The New Yorker. N.p., 2016. Web. 18 Jan. 2017.

[12] Smith, Richard. “Deutsche Bank And A $10Bn Money Laundering Nightmare: More Context Than You Can Shake A Stick At”. Naked Capitalism. N.p., 2017. Web. 18 Jan. 2017.

[13] New York State Department of Financial Services (DFS),. DFS FINES DEUTSCHE BANK $425 MILLION FOR RUSSIAN MIRROR-TRADING SCHEME. 2017. Web. 25 Jan. 2017.

[14] Caesar, Ed. “A Big Fine, And New Questions, On Deutsche Bank’s “Mirror Trades””. The New Yorker. N.p., 2017. Web. 22 Feb. 2017.

[15] Williams-Grut, Oscar. “Deutsche Bank Is Paying $628 Million In Fines Over Its $10 Billion Russian ‘Mirror Trade’ Scandal”. Business Insider Australia. N.p., 2017. Web. 19 Jan. 20 17.

[16] Williams-Grut, Oscar. “Deutsche Bank Is Paying $628 Million In Fines Over Its $10 Billion Russian ‘Mirror Trade’ Scandal”. Business Insider Australia. N.p., 2017. Web. 19 Jan. 20 17.

[17] New York State Department of Financial Services (DFS),. DFS FINES DEUTSCHE BANK $425 MILLION FOR RUSSIAN MIRROR-TRADING SCHEME. 2017. Web. 25 Jan. 2017.

[18] New York State Department of Financial Services (DFS),. DFS FINES DEUTSCHE BANK $425 MILLION FOR RUSSIAN MIRROR-TRADING SCHEME. 2017. Web. 25 Jan. 2017.

[19] Caesar, Ed. “Deutsche Bank’S $10-Billion Scandal”. The New Yorker. N.p., 2016. Web. 18 Jan. 2017.

[20] Caesar, Ed. “Deutsche Bank’S $10-Billion Scandal”. The New Yorker. N.p., 2016. Web. 18 Jan. 2017.

[21] New York State Department of Financial Services (DFS),. DFS FINES DEUTSCHE BANK $425 MILLION FOR RUSSIAN MIRROR-TRADING SCHEME. 2017. Web. 25 Jan. 2017.

[22] Caesar, Ed. “A Big Fine, And New Questions, On Deutsche Bank’s “Mirror Trades””. The New Yorker. N.p., 2017. Web. 22 Feb. 2017.

[23] Caesar, Ed. “Deutsche Bank’S $10-Billion Scandal”. The New Yorker. N.p., 2016. Web. 18 Jan. 2017.

[24] New York State Department of Financial Services (DFS),. DFS FINES DEUTSCHE BANK $425 MILLION FOR RUSSIAN MIRROR-TRADING SCHEME. 2017. Web. 25 Jan. 2017.

[25] Caesar, Ed. “Deutsche Bank’S $10-Billion Scandal”. The New Yorker. N.p., 2016. Web. 18 Jan. 2017.

[26] New York State Department of Financial Services (DFS),. DFS FINES DEUTSCHE BANK $425 MILLION FOR RUSSIAN MIRROR-TRADING SCHEME. 2017. Web. 25 Jan. 2017.

[27] New York State Department of Financial Services (DFS),. DFS FINES DEUTSCHE BANK $425 MILLION FOR RUSSIAN MIRROR-TRADING SCHEME. 2017. Web. 25 Jan. 2017.

[28] New York State Department of Financial Services (DFS),. DFS FINES DEUTSCHE BANK $425 MILLION FOR RUSSIAN MIRROR-TRADING SCHEME. 2017. Web. 25 Jan. 2017.

[29] Caesar, Ed. “Deutsche Bank’S $10-Billion Scandal”. The New Yorker. N.p., 2016. Web. 18 Jan. 2017.

[30] Caesar, Ed. “Deutsche Bank’S $10-Billion Scandal”. The New Yorker. N.p., 2016. Web. 18 Jan. 2017.

[31] Caesar, Ed. “Deutsche Bank’S $10-Billion Scandal”. The New Yorker. N.p., 2016. Web. 18 Jan. 2017.

[32] Caesar, Ed. “Deutsche Bank’S $10-Billion Scandal”. The New Yorker. N.p., 2016. Web. 18 Jan. 2017.

[33] New York State Department of Financial Services (DFS),. DFS FINES DEUTSCHE BANK $425 MILLION FOR RUSSIAN MIRROR-TRADING SCHEME. 2017. Web. 25 Jan. 2017.

[34] Caesar, Ed. “Deutsche Bank’S $10-Billion Scandal”. The New Yorker. N.p., 2016. Web. 18 Jan. 2017.

[35] New York State Department of Financial Services (DFS),. DFS FINES DEUTSCHE BANK $425 MILLION FOR RUSSIAN MIRROR-TRADING SCHEME. 2017. Web. 25 Jan. 2017.

[36] Caesar, Ed. “Deutsche Bank’S $10-Billion Scandal”. The New Yorker. N.p., 2016. Web. 18 Jan. 2017.

[37] Caesar, Ed. “Deutsche Bank’S $10-Billion Scandal”. The New Yorker. N.p., 2016. Web. 18 Jan. 2017.

[38] New York State Department of Financial Services (DFS),. DFS FINES DEUTSCHE BANK $425 MILLION FOR RUSSIAN MIRROR-TRADING SCHEME. 2017. Web. 25 Jan. 2017.

[39] Caesar, Ed. “Deutsche Bank’S $10-Billion Scandal”. The New Yorker. N.p., 2016. Web. 18 Jan. 2017.

[40] Farrell, Greg, Keri Geiger, and Suzi Ring. “Deutsche Bank Said Near Mirror-Trade Deal With U.K., N.Y.”. Bloomberg (2017): n. pag. Web. 20 Jan. 2017.

[41] New York State Department of Financial Services (DFS),. DFS FINES DEUTSCHE BANK $425 MILLION FOR RUSSIAN MIRROR-TRADING SCHEME. 2017. Web. 25 Jan. 2017.

[42] New York State Department of Financial Services (DFS),. DFS FINES DEUTSCHE BANK $425 MILLION FOR RUSSIAN MIRROR-TRADING SCHEME. 2017. Web. 25 Jan. 2017.

REFERENCES

Lee, Peter. “Can Cryan Halt Deutsche Bank’s Decline?”. EuroMoney. N.p., 2016. Web. 18 Jan. 2017. Available at: http://www.euromoney.com/Article/3534126/Can-Cryan-halt-Deutsche-Banks-decline.html

“Deutsche Bank – History”. Deutsche Bank Russia. Web. 18 Jan. 2017. Available at: https://www.db.com/russia/en/content/765.htm

“Organization, Mission & Functions Manual: Attorney General, Deputy And Associate, Department Of Justice”. The United States Department of Justice. N.p., 2014. Web. 18 Jan. 2017. Available at: https://www.justice.gov/jmd/organization-mission-and-functions-manual-attorney-general

“NYSDFS: Mission And Leadership”. New York State Department of Financial Services. Web. 18 Jan. 2017. Available at: http://www.dfs.ny.gov/about/mission.htm

“About Us”. Organized Crime and Corruption Reporting Project. N.p., 2007. Web. 18 Jan. 2017. Available at: https://www.occrp.org/en/about-us

“Mirror Trading”. Investopedia. Web. 18 Jan. 2017. Available at: http://www.investopedia.com/terms/m/mirror-trading.asp

“Task Force: ELIGO Factsheet”. Australian Crime Commission, Australian Federal Police, AUSTRAC. Web. 18 Jan. 2017. Available at: http://www.austrac.gov.au/sites/default/files/documents/eligo_ml_fact_sheet.pdf

Caesar, Ed. “Deutsche Bank’S $10-Billion Scandal”. The New Yorker. N.p., 2016. Web. 18 Jan. 2017. Available at: http://www.newyorker.com/magazine/2016/08/29/deutsche-banks-10-billion-scandal

Smith, Richard. “Deutsche Bank And A $10Bn Money Laundering Nightmare: More Context Than You Can Shake A Stick At”. Naked Capitalism. N.p., 2017. Web. 18 Jan. 2017. Available at: http://www.nakedcapitalism.com/2016/09/deutsche-bank-and-a-10bn-money-laundering-nightmare-more-context-than-you-can-shake-a-stick-at.html

“US Doj Hits Deutsche Bank With Record $14Bn Fine”. The Local Germany (2016). N.p., 2017. Web. 18 Jan. 2017. Available at: https://www.thelocal.de/20160917/us-doj-hits-deutsche-bank-with-record-14bn-fine

Farrell, Greg, Keri Geiger, and Suzi Ring. “Deutsche Bank Said Near Mirror-Trade Deal With U.K., N.Y.”. Bloomberg (2017): n. pag. Web. 20 Jan. 2017. Available at: https://www.bloomberg.com/news/articles/2017-01-30/deutsche-bank-said-to-be-near-mirror-trade-deal-with-u-k-n-y

Williams-Grut, Oscar. “Deutsche Bank Is Paying $628 Million In Fines Over Its $10 Billion Russian ‘Mirror Trade’ Scandal”. Business Insider Australia. N.p., 2017. Web. 19 Jan. 20 17. Available at: http://www.businessinsider.com.au/deutsche-bank-russian-mirror-trades-settles-uk-fca-new-york-regulator-2017-1?r=UK&IR=T

New York State Department of Financial Services (DFS),. DFS FINES DEUTSCHE BANK $425 MILLION FOR RUSSIAN MIRROR-TRADING SCHEME. 2017. Web. 25 Jan. 2017. Available at: http://www.dfs.ny.gov/about/press/pr1701301.htm

Caesar, Ed. “A Big Fine, And New Questions, On Deutsche Bank’s “Mirror Trades””. The New Yorker. N.p., 2017. Web. 22 Feb. 2017. Available at: http://www.newyorker.com/business/currency/a-big-fine-and-new-questions-on-deutsche-banks-mirror-trades

 

Photo Courtesy of The International Reporter 

 

 

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