“The Board of Directors takes it very seriously that historically we were not good enough at preventing money laundering at our branch in Estonia. That is why we have launched thorough and comprehensive investigations of the conditions in Estonia during the period in question. The investigations are led by external counsel to ensure objectivity and completeness, and the investigations report to the Board of Directors. The investigations are conducted in cooperation with leading Danish and international experts who provide expertise in fields such as data analysis and forensic experience. This is a complex issue that involves examination of comprehensive material, such as documents, presentations and e-mails, and very large volumes of transaction data. That is why the investigations are taking longer than we would have preferred.”
“We fully understand the extensive interest in the matter, and we are strongly committed to getting to the bottom of it and sharing our conclusions. As earlier stated, the investigations may take up to 12 months to complete, and we expect to be able to share our findings by September 2018. We may be able to draw partial conclusions before then. Until we have a sufficient factual basis, it would be wrong to comment further on the details of the case. Should the investigations uncover misconduct on the part of employees or managers, we will of course ensure that the necessary steps are taken.”
Facts on the investigations and the parties involved
- In the spring of 2017, Danske Bank initiated a so-called root cause analysis of the situation at Danske Bank’s branch in Estonia. This analysis pointed to a combination of factors, which meant that we were not sufficiently effective in preventing the Estonian branch from potentially being used for money laundering.
- On the back of this analysis, Danske Bank launched thorough investigations in the autumn of 2017 of the conditions in Estonia. Generally, the investigations focus on two areas:
- A thorough examination of customers and transactions at the Estonian branch in the period from 2007 to 2015. As part of this, the extent of suspicious transactions will be uncovered, and any relevant matters that have not already been reported to the authorities will be reported. It will also determine whether there are employees who, actively or otherwise, contributed to such transactions.
- An examination of who knew what and when, both in Estonia and at Group level, and to determine whether managers and employees lived up to their responsibilities to a sufficient degree.
- The investigations report to Danske Bank’s Board of Directors, and the Board receives regular updates.
- The law firm Bruun & Hjejle will lead and supervise the investigations and prepare the final report when the investigations have been completed.
- The investigation into all foreign customers and transactions at the Estonian branch from 2007 to 2015 is conducted by Danske Bank’s Compliance Incident Management Team, headed by Jens Madsen, former head of Denmark’s intelligence agency and the Fraud Squad (PET and SØIK).
- The investigations are also conducted in cooperation with Danish and international experts:
- The international data analysis software company Palantir Technologies. This company provides a platform for analysing the original transaction and customer data.
- The consultancy firms PwC and EY. They provide forensic experience.
- The US-based consultancy firm Promontory. This firm provides expert knowledge in the fields of AML and AML controls.