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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.

We have finalised the delivery of a comprehensive Group-wide, multi-year enhancement programme – and we continue to test and invest in our systems, controls and competencies to protect Danske Bank and our customers from financial crime.

We are committed to preserving the integrity of our business and upholding our societal responsibility.

How we fight financial crime

We adhere to Finance Denmark's principles

At Danske Bank, we adhere to the principles developed by Finance Denmark’s Anti-Money Laundering and Counter-Terrorist Financing Taskforce in which we participated, to prevent and combat money laundering and terrorist financing. These principles are reflected in our approach.

Principle 1

We always prioritise ethics over profit

Principle 2

We comply with the spirit and the letter of the law

Principle 3

We welcome oversight

Principle 4

We have a targeted corporate culture commitment

Principle 5

We assume managerial responsibility and ensure that all staff take responsibility for AML/CTF efforts

Principle 6

We have constructive partnerships with all stakeholders, including the authorities

We focus on people, partnerships and processes

  • We ensure that we have the right PEOPLE and competencies in place to fight financial crime..


    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

  • We continually develop our PROCESSES, controls, and systems to maintain our ability to effectively prevent financial crimes. 


    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.

    • Financial sanctions

    Danske Bank complies with financial sanctions imposed by the UN, the EU, the UK, the USA, and any other applicable sanctions as appropriate.

    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.

    Danske Bank’s policy towards specific countries, areas, sectors, etc. might be more restrictive than applicable financial sanctions due to the overall financial crime risk associated with the specific country, area, or sector. 

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

Our Three-Lines-of-Defence ensures effective governance

The-Three-Lines-of-Defence-Model is a key element in ensuring effective governance and oversight of financial crime 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 1st Line of Defence. Includes Group Compliance and Group Risk Management.

The 3rd Line of Defence is an independent 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.

How this affects customers

Preventing and fighting financial crime are two essential tasks that every responsible financial institution must perform. That is why we at Danske Bank have both an obligation and a commitment to comply with Danish and international anti-money laundering legislation and regulations and to fight money laundering and fraud against banks and customers. 

Among other things, this means that we continuously update our knowledge of our customers and their use of our products and services, carefully monitor transactions and cooperate closely with authorities in and outside Denmark

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.


Policies

Financial Crime Policy

Our group-wide Financial Crime Policy is a crucial part of our overall Compliance Framework. The Policy sets out the principles and standards for the management of risk and compliance associated with Money Laundering, Terrorist Financing, Sanctions, Bribery, Corruption, Fraud (Internal and External), Tax Evasion and Facilitation of Tax Evasion in the Group.

Download Financial Crime Policy

 

Whistleblowing

Danske Bank is committed to conducting business with integrity and doing the right thing for our customers, colleagues and society. We encourage all those who have serious concerns they wish to report, to make use of our Whistleblowing Scheme, where they can report in confidence and – if they choose to do so - anonymously.

Report here
Download Whisteblowing policy