Danske Bank A/S

The Central Bank has determined the appropriate fine to be €2,600,000, which has been reduced by 30%2 to €1,820,000 in accordance with the early settlement discount scheme provided for in the Central Bank’s Administrative Sanctions Procedure (ASP). This is the first penalty that the Central Bank has imposed on a financial institution which is incorporated and supervised outside of Ireland (i.e. in Denmark) but which operates in Ireland as a branch on a passport basis3. The Central Bank has responsibility for Anti-Money Laundering / Countering the Financing of Terrorism (AML/CFT) supervision of Danske’s branch operations in Ireland. The three breaches comprised of failures by Danske under the CJA relating to:  Transaction Monitoring: Danske failed to ensure that its automated transaction monitoring system monitored the transactions of certain categories of customer for money laundering and terrorist financing risk at its Irish branch for a period of almost nine years.  Enhanced Customer Due Diligence: In failing to conduct automated transaction monitoring in respect of certain categories of customers, Danske’s Irish branch did not take into consideration an important part of due diligence i.e. transaction monitoring data, which is necessary to identify and assess money laundering/terrorist financing risks specific to those customers and identify where any consequential additional measures might be required.  Anti-money laundering / Countering the Financing of Terrorism policies, procedures and controls: The policies, procedures and controls put in place by Danske did not operate to identify the erroneous exclusion of certain categories of customers from automated transaction monitoring. The three breaches have been admitted by Danske.