Key initiatives

• Fighting financial crime is a top priority 

We 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 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.

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’.

• 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.

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.