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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 made substantial investments to improve our financial crime prevention systems, controls and competencies and have undertaken a comprehensive group-wide, multi-year enhancement programme. We have come far, and continuing these efforts to preserve the integrity of our business and uphold our societal responsibility remains at the top of our agenda.

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 combat financial crime.


    Key initiatives

    • Fighting financial crime is a top priority 

    DWe have implemented an enhanced governance structure to ensure venues for the escalation of any compliance matters to the Executive Leadership Team and the Board of Directors. 

    As an example, our Chief Compliance Officer has a direct reporting to the Executive Leadership Team as well as the Board of Directors, ensuring that compliance and the fight against financial crime is an integrated part of how we do business.

    We continuously work towards ingraining financial crime prevention in our organisational DNA and foster a shared mind-set, where employees always think about doing the right business with the right people in the right way.

    • Mandatory fighting financial crime training of all employees

    As part of Danske Bank’s mandatory compliance training, all employees must complete an annual e-learning curriculum on fighting financial crime.

    We also provide targeted financial crime 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.

    • An essential part of our business

    We have recruited experienced employees with Financial Crime expertise into new roles and enhanced functions as part of strengthening our competences across our three lines of defence.

    Today, we have more than 3,000 full-time employees working on our financial crime prevention agenda across the Danske Bank organisation, which  makes up approximately 17% of all employees of Danske Bank.

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

    Key initiatives 

    • Supporting a stronger industry framework to combat financial crime

    Danske Bank contributes with expertise and policy recommendations for a more efficient and effective industry framework to prevent money laundering and counter-terrorist financing.

    We also participate actively in the ongoing development of shared IT solutions and standards across the Danish banking industry through the industry consortium ’e-nettet’
    .

    • Nordic collaboration on Know-Your-Customer (KYC) information

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

    In 2018, together with five leading banks in the Nordic region, Danske Bank developed a Nordic KYC Utility to enhance and simplify Know-Your-Customer (KYC) processes for corporate customers, while strengthening financial crime prevention in the Nordic region.

    Today, the six founding banks own an equal share of an autonomous private company, Invidem, which offers compliant KYC information to banks and other financial institutions across the Nordics based on a shared KYC standard co-developed by the founding banks. 

    • Participation in public private partnerships

    Danske Bank actively engages in initiatives to collectively combat 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 within the Nordic countries.

    In addition, we also provide 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 work to improve our PROCESSES, controls and systems to enhance our ability to prevent financial crimes  


    Key initiatives

    • Improving 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 clients of Danske Bank, and how they intend to use our services.

    We have refined and launched new digital platforms and tools to optimise our Know-Your-Customer (KYC) data collection and enhance quality of existing KYC data, allowing us to validate the data faster and make it easier to become a client of Danske Bank. These initiatives include using our customers' preferred digital communications channels for data collection.

    • 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.

    • Continued enhancement of transaction monitoring systems

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

    We have expanded our automated monitoring and surveillance of transactions and communications by utilising technologies to optimise the process and target relevant risks, and we continue to strengthen our systems to identify potentially unusual patterns by implementing new and improved technologies.

    • Improved investigation and reporting

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

    We have enhanced the coverage of our investigations and the speed in which our investigators are able to identify potential financial crime risks by implementing new data analytics and visualisation systems. This provides both our management and relevant authorities with higher quality suspicious activity reports.

    • Complying with 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. 

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

    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

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 anti-money laundering framework and continuously update customer information.

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

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