First and foremost, it important to state that we will probably never completely eradicate money laundering. The banking community is doing a great deal, but the criminals and the networks that they are part of are becoming more and more sophisticated and are always trying to circumvent our systems and controls.
Today, the situation is different when it comes to the combating of money laundering than it was when the case developed in Estonia. We have rectified the situation in Estonia and have ensured, among other things, that the portfolio in question was closed down. Also, we decided – and this applies in all three Baltic countries – to focus only on Nordic customers and global customers with a solid Nordic footprint. Governance and oversight in relation to the Baltic units have been strengthened, for example with the introduction of a new pan-Baltic management. In addition, the independence of local control functions has been strengthened to ensure the same level of control as in other parts of the Group.
We have strengthened our efforts to combat financial crime, including money laundering significantly and have invested considerably in improving all three lines of defence (business, compliance and audit). Thus, more than 1,200 employees now work in this area.
We have initiated a comprehensive AML programme, which has led to new organisational structures, new routines and procedures, We have also implemented new and shared IT systems in the Baltic countries, which ensure better integration with the rest of the Group and a higher degree of transparency and control.
We continue to strengthen the compliance knowledge and culture across our organisation.
Over the past 12 months, our 20,000 employees have spent a total of 46,000 hours on 63 e-learning modules dealing, among other things, with preventing financial crime, including money laundering.
Last, but not least, we invest in automating business procedures and upgrading the IT systems that support those procedures. We are also improving the “know-your-customer” procedures used when welcoming new customers to Danske Bank. This gives us a far better overview and better monitoring of our customer’s activities.