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.

Finance Denmark's principles for fighting financial crime

At Danske Bank, we adhere to the principles developed by Finance Denmark to prevent and combat money laundering and terrorist financing:

  1. We always prioritise ethics over profit
  2. We comply with the spirit and the letter of the law
  3. We welcome oversight
  4. We have a targeted corporate culture commitment
  5. We assume managerial responsibility and ensure that all staff take responsibility for AML/CTF efforts
  6. We have constructive partnerships with all stakeholders, including the authorities

These principles are reflected in our approach.

Our approach


  • PEOPLE - ensure the right people and competences
    We are making significant changes to ensure that we have the right PEOPLE and competences in place to combat financial crime. 


    Key initiatives

    • Fighting financial crime is a top priority 

    Danske Bank is investing heavily to improve financial crime prevention systems, controls and competencies and have undertaken a comprehensive group-wide, multi-year enhancement programme. Continuing these efforts remains at the top of our agenda in years to come.

    In cooperation with, and under responsibility of the CEO at Danske 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.

    As an important part of our progress, we 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 continue to recruit experienced employees with Financial Crime expertise into new roles and enhanced functions as part of strengthening our competences across our 1st and 2nd line of defence within compliance and financial crime prevention.

    Today, over 10% of Danske Bank’s employees are dedicated full-time towards our fighting financial crime agenda.

  • PARTNERSHIPS - engage proactively with authorities and industry colleagues

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

    Key initiatives 

    • Joint IT solutions across the industry

    Danske Bank supports the development of a joint anti-money laundering and counter-terrorist financing utility for the financial sector in Denmark.

    We work to ensure this through the industry consortium 'e-nettet’, where we actively participate in the ongoing development of shared IT solutions and standards across the Danish banking industry.

    • 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.

    • 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.

    • 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 Finland and Lithuania.

    • 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.

  • PROCESSES - improve our processes, controls and systems
    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.

    Moreover, with limited exceptions, we do not facilitate any business or transactions involving North Korea, Iran, Syria and the Crimea territory of Ukraine. 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.

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.

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 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.

Policies

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

  • 11. maj 2021Financial Crime Policy
  • 06. feb 2019Code of Conduct Policy
  • 13. nov 2020Whistleblowing Policy

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.

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

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