BaFin Deutsche AML Order

On Sep. 24, BaFin ordered Deutsche Bank to do more on AML/CTF.

  • Announced order re measures to prevent money laundering and terrorist financing.
  • Followed Deusche Bank AML failings, US/UK fines.


  • Order was made Sep. 21, 2018 under money laundering act (GwG), section 51(2).
  • In the order made by BaFin, it formally required that Deutsche Bank AG must take appropriate internal safeguards and comply with general due diligence obligations.
  • To monitor implementation, BaFin appointed special representative (KPMG) under with banking act (KWG), section 45c(1), (2) no. 6, to assess progress and report.