Key initiatives

• Fighting financial crime is a top priority 

We have governance structures in place to ensure escalation of compliance matters when required.

Our Chief Compliance Officer is a member of our Executive Leadership Team, ensuring that compliance and the fight against financial crime is an integrated part of how we do business.

Financial crime prevention is part of our organisational DNA and we nurture a shared mind-set, where employees are mindful of doing the right kind of business with the right customers in the right way.

• Mandatory fighting financial crime training 
  

All employees are required to complete mandatory training in fighting financial crime every year.

We also provide targeted financial crime prevention training to employees throughout the organisation, ranging from senior management to frontline advisors. This specialised training considers different learning objectives that are specific to certain roles and includes feedback loops to ensure that we are learning from the past.

• An essential part of our business
  

We have experienced financial crime prevention specialists in our organisation, and we maintain strong competencies across our three lines of defence.

We engage proactively with authorities and industry colleagues in PARTNERSHIPS to fight financial crime together. 

Key initiatives 

• Supporting a stronger industry framework

Danske Bank contributes expertise and policy recommendations to create a more efficient and effective industry framework for preventing money laundering and countering terrorist financing.

• Participation in public private partnerships

Danske Bank actively engages in initiatives to collectively fight financial crime by increasing cooperation between the financial sector and authorities.

One example is our participation in the Swedish Anti Money Laundering Initiative (SAMLIT), where the police and the five largest banks in Sweden join forces on high profile financial crime investigations, using new methods for sharing information under current legislation. In addition, we are involved in similar initiatives in Norway, Finland and Denmark.

• Joint efforts against cybercrime

Danske Bank collaborates with external cyber security organisations to help strengthen cyber resilience in the Nordic countries.

In addition, we also provide advice and tools for our customers that enable them to protect themselves against cyber criminals and payment fraud, such as investment scams, romance scams, crypto-currency scams, and ID theft.

To raise awareness of fraud trends, we also collaborate with the Danish Consumer Council on their free self-defence app, Mit digitale forsvar

Key initiatives

• Customer on-boarding and data quality

As a bank, we are required by law to review our customers to better understand who they are, why they want to become customers of Danske Bank, and how they intend to use our services.

We use digital platforms and tools to optimise our Know-Your-Customer (KYC) data collection and ensure the quality of existing KYC data, allowing us to validate the data quickly and making it easy to become a customer of Danske Bank.

• International money transfers
  

We require complete information about the payer and recipient of international payments.

This means that several items of information about the payer and recipient must follow the transaction throughout the payment process. The purpose of these requirements is to prevent, investigate and trace money laundering and the financing of terrorism and to ensure that international payments are secure.

• Transaction monitoring systems

Monitoring and screening of customers and their transactions are a vital part of Danske Bank's financial crime defence.

We undertake automated monitoring and surveillance of transactions and communications by utilising technologies to optimise the process and target relevant risks, and we continue to ensure that our systems are fit to identify potentially unusual patterns.

• Investigation and reporting

At Danske Bank, we pursue investigation efficiency and effectiveness to ensure that any suspicion of financial crime is reported to the relevant authorities for further investigation.

We continue to ensure that the speed and coverage of our investigations are fit to identify potential financial crime risks. 

We use data analytics and visualisation systems to provide both our management and relevant authorities with higher quality suspicious activity reports.

• Complying with financial sanctions
  

Danske Bank complies with all legally applicable financial sanctions, including sanctions imposed by the UN, the EU and jurisdictions in which Danske Bank operates, including the UK. In addition, Danske Bank complies with US sanctions to the required extent due to the extraterritorial nature of those sanctions and for overall risk management reasons.

At Danske Bank, we have processes in place to ensure that we do not offer banking services to sanctioned parties and that we do not engage in transactions or activities in violation of sanctions.

Due to the overall financial crime risk associated with a specific country, area or sector, Danske Bank’s policy towards specific countries, areas, sectors, etc. may be more restrictive than applicable financial sanctions. We generally do not facilitate any business or transactions involving North Korea, Iran, Syria and the territories of Donetsk, Luhansk, Crimea and any other territory not under the control of the Ukrainian government. Following Russia’s invasion of Ukraine, we have implemented a restrictive approach to any new business or activities involving Russia or Belarus. We also maintain a limited financial crime risk position for activities involving Cuba.

We may consider processing specific transactions involving these territories, such as transactions related to humanitarian aid, if we receive a request from our customer in advance.

We may, in our sole discretion, decide not to process transactions or provide certain products or services or decide to otherwise decline to facilitate transactions in cases where these activities fall outside Danske Bank’s risk appetite.