Fighting financial crime

Access to the financial system helps transform lives around the world, helping people to realise their goals and spurring economic development.

However, the financial system is also used by criminals for some of today’s most damaging crimes – from human trafficking to terrorism.

At Danske Bank, we are committed to fighting financial crime. Continuing to strengthen and improve our efforts to preserve the integrity of our business and uphold our societal responsibility is a key priority for us.
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The solution


  • PEOPLE
    We ensure that we have the right PEOPLE and capabilities, and we continuously work to instil a culture of vigilance about fighting financial crime in the bank.


    Key initiatives

    • Fighting financial crime is a top priority 

    In cooperation with and under responsibility of the CEO of the bank, the Chief Compliance Officer reports to the Board of Directors, ensuring that compliance and the fight against financial crime is an integrated part of how we do business.

    • Mandatory training of employees

    All employees receive annual mandatory training and tests in how to prevent financial crime. All modules are designed to train staff in the regulatory requirements, and at the same time they provide examples, cases and instructions tailored to Danske Bank’s own processes and frameworks. 

    • Important part of our business 

    More than 10% of all employees across our 1st and 2nd line of defence currently work with compliance and combatting financial crime.   

  • PARTNERSHIPS

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

    Key initiatives 

    • Joint IT-solutions across the industry

    We support the development of a joint AML/CFT (anti-money laundering / combating the financing of terrorism) utility for the financial sector in Denmark. We work to ensure this through the industry consortium 'e-nettet’

    • Nordic KYC utility

    Know Your Customer (KYC) rules require us to understand and document who our customers are, what the purpose of their business is and how they actually use the bank. Together with the five largest banks in the Nordic countries, we are now developing a platform for handling and administrating KYC datafor corporate customers, thereby making it easier for them to bank with Danske Bank while at the same time strengthening the prevention of financial crime. 

    • Supporting a stronger AML/CFT framework to combat financial crime

    We are  contributing with our experience and concrete policy recommendations for a more efficient and effective framework for fighting financial crime.    

  • PROCESSES
    We continually work to improve our PROCESSES, and consequently our defence systems, against financial crime.


    Key initiatives

    • Optimisation of data quality and new ways of onboarding clients

    Know Your Customer (KYC) rules require us to understand and document who our customers are, what the purpose of their business is and how they actually use the bank. We have launched several initiatives to improve the quality of our existing Know-Your-Customer (KYC) data, allowing us to validate this data faster.

    • Continued enhancement of transaction monitoring systems

    We continue to strengthen our systems to be able to identify an increased number of potentially unusual patterns (“scenarios”) in customer behavior or transactions. 

    • Digital KYC-solutions

    These will make it easier and less burdensome for customers to update their data, for example by providing easy access via Danske Mobile Banking and by providing easy-to-complete online questionnaires.

    • Financial sanctions

    Danske Bank complies with financial sanctions imposed by the UN, the EU and the USA (Office of Foreign Assets Control (OFAC)), and we have clear procedures in this area.  

    We have various processes in place to ensure compliance with international financial sanctions, including restrictions related to payments that involve certain countries.

    • Requirements for 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.

How this affects customers

Like all other banks in the EU, we must follow the ‘Know Your Customer’ rules, which means that we must understand and document who our customers are, what the purpose of their business at the bank is and how they actually use the bank.

We understand that customers can feel a little inconvenienced or even irritated when we ask for information and a copy of their proof of identity. However, just as the security check at the airport ensures that all travellers can enjoy a safe journey, it is both necessary and in the interest of us all that we comply with the rules, strengthen our AML framework and continuously update customer information.
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Danske Bank's Three-Lines-of-Defence 

The-Three-Lines-of-Defence-Model is a key element in ensuring effective governance and oversight of money laundering, terrorist financing and sanctions risk - including ensuring that clearly defined roles and responsibilities are in place.

The 1st Line of Defence owns and manages business activities and related risks. Includes business units and Group functions (e.g. operations, HR and finance).  

The 2nd Line of Defence provides risk management framework and performs risk oversight. Supports and challenges the first line. Includes Group Compliance and Group Risk Management.  

The 3rd Line of Defence is an i
ndependent and objective unit (Internal Audit) evaluating and improving the effectiveness of risk management, control and governance processes in relation to the control environments of the 1st  and  2nd Lines of Defence.

Investigations into the closed Estonian branch

In 2017, Danske Bank initiated an external investigation by the Danish law firm Bruun & Hjejle into our Estonian branch.

The investigations showed that from 2007 and 2015 reprehensible conditions at our Estonian branch and at Group level allowed Danske Bank’s branch in Estonia to be misused for suspicious transactions, and they also showed that we reacted too late and too slowly.

This led us to strengthen our efforts on fighting financial crime, in order to preserve the integrity of our business and uphold our societal responsibility. 

Danske Bank closed all banking activities in Estonia by end of 2019.

Look into the investigation

Whistleblowing policy

Danske Bank is committed to encouraging employees to speak up about suspected wrongdoing as soon as possible. We are committed to ensuring that our employees can raise their concerns in the knowledge that these will be taken seriously and investigated fully. 

Our whistleblowing system is an internal reporting channel that provides employees and others with a safe, simple and uniform way of raising concerns when regular channels of communication and escalation are unavailable, inappropriate or compromised. Reports and questions received through the whistleblower system are treated as strictly confidential, and they are forwarded to Group Compliance and the Board of Directors' Audit Committee.

Policies

To ensure strong governance and a strong culture of compliance, clear policies are crucial.

  • 06. feb 2019Code of Conduct Policy
  • 05. maj 2020AML CTF and Sanctions Policy
  • 16. jun 2020Whistleblowing Policy