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Discounts on foreign exchange trades and foreign exchange in connection with international payments 

Across our markets, some customers, primarily business customers, have not received the correct discounts on foreign exchange trades and foreign exchange in connection with international payments because the discounts were not registered correctly in our system in the period from 2009 to 2021. We will reimburse the excess amount paid by the customers affected. We have tightened our procedures and have implemented an updated IT infrastructure to minimise the risk of similar errors.

Customers affected and information to them

Across our markets, around 3,800 customers may potentially be impacted by the issue. Around 1,100 of the customers have not received the correct discounts due to erroneous registrations in our discount systems, and these customers will be reimbursed for the excess amount paid as soon as possible.

For the rest of the customers, we assess that there is a minimal risk that they are impacted, as there are not indications of erroneous registrations for these customers. All customers will receive new discounts agreements serving as documentation for the discounts to which they are entitled.

It was our expectation that we, before year-end, would have been able to reimburse the excess amount paid by the customers affected.  Due to the complexity of the issue, the repayment has, unfortunately, been further delayed. We have now repaid about half of the affected customers, and apart from special cases, we expect to have made the remaining repayments before the end of June 2022.

During the remediation work, we have recently identified a smaller number of additional cases that are potentially also affected by this issue. We are looking into these and affected customers will be contacted directly.

Numbers below updated 3 June 2022

Around 1,100 customers affected

Half of the affected customers have received compensation

Timeline

  • Affected customers begin to receive compensation.
  • We finalise our analysis of potentially affected customers and find that, across our markets, around 3,800 customers may potentially be impacted by the issue. Around 1,100 of the customers have not received the correct discounts due to erroneous registrations in our discount systems, and these customers will be reimbursed for the excess amount paid as soon as possible. For the rest of the customers, we assess that there is a minimal risk that they are impacted, as there are not indications of erroneous registrations for these customers. All customers will receive new discounts agreements serving as documentation for the discounts to which they are entitled.

  • Based on our initial review of historic foreign exchange trades and foreign exchange in connection with international payments, we identify in October 2020 up to 3,000 customers who potentially have not received the discounts to which they are entitled, which we need to investigate further. We begin notifying the first group of potentially affected customers by phone and letters to inform them of the issue and that they may be affected.

  • In January 2020, we tighten our procedures and start implementing an updated IT infrastructure to prevent the error from reoccurring.

  • In September 2019, we start to review foreign exchange trades and foreign exchange in connection with international payments to determine which customers who may not have received the agreed rebates.

  • In August 2019, we identify an incorrect registration of a rebate on foreign exchange trades and international payments. To assess the root cause, scope and significance of the issue, we initiate an internal review, which made it clear that the issue was of a more systemic nature.

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