Deutsche Bank AG - 2017
|Banking & Finance
|State Attorney General
|NY Department of Financial Services
|January 30, 2017
|Monitor Reference Term:
|Monitor Selection Process:
WIll be selected by the Reporting Agency, which will determine whether one of the two existing Monitors currently in place may expand its assignment. NYDFS usually issues a public request for applicants.
|Time to Propose Monitors:
|Time to Engage Monitor:
|Time to First Report:
|Monitor Required Qualifications:
Not specified in Agreement.
|Summary of Monitor's Scope:
Conduct a comprehensive review of the Host Organization's existing BSA/AML compliance programs, polices and procedures that pertain to or affect activities conducted by or through a) DBTCA and b) the New York branch.
|Summary of Monitor's Activities:
Review and report on (at a minimum): 1) the elements of the Host Organization's corporate governance that contributed to or facilitated the improper conduct and permitted it to go on, relevant changes or reforms, and whether those reforms are likely to significantly enhance BSA/AML compliance going forward; 2) the thoroughness and comprehensiveness of current BSA/AML compliance programs, including, but not limited to, compliance programs designed to address the conduct at issue; 3) the organizational structure, management oversight, and reporting lines relevant to BSA/AML compliance, and an assessment of the staffing of BSA/AML compliance teams globally, including the duties, responsibilities, authority, and competence of officers or employees responsible for compliance with laws and regulations pertaining to BSA/AML compliance; 4) the proprietary, reasonableness and adequacy of any proposed, planned, or recently instituted changes to the BSA/AML compliance programs; and 5) any corrective measures necessary to address identified weaknesses or deficiencies in the corporate governance or its global BSA/AML compliance programs. Monitor will oversee the implementation of any corrective measures undertaken pursuant to his/her report as agreed by parties and assess on-going compliance.
None specified in Agreement.