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 | Enforcement Action Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Enforcement Action Dataset

 
In the Matter of Deutsche Bank AG · Deutsche Bank's Involvement in Asia between 2006 and 2015

Case Information

In the Matter of Deutsche Bank AG

Related FCPA Matter:   Deutsche Bank's Involvement in Asia between 2006 and 2015 Information

Case Information

Initiation Date:    08/22/2019  Information

Prosecuting Agency:    U.S. Securities and Exchange Commission

Type of Action:    SEC Administrative Proceeding

Docket or Case Number:    3-19373

Name of Prosecuting Attorneys:   

  • Jennifer Moore, SEC Salt Lake Regional Office
  • Tanya G. Beard, SEC Salt Lake Regional Office
  • Daniel Wadley, SEC Headquarters

US Assisting Agencies:   

  • U.S. Department of Justice

Foreign Enforcement Action/Investigation:    Unknown

Foreign Assistance:    Unknown

Origin of the Proceeding:    Unknown

Whistleblower:    Unknown

Case Status:    Resolved


Summary  Information

Deutsche Bank AG, incorporated and headquartered in Germany, was a multinational financial services corporation with operations in more than 70 countries worldwide. The company issued and maintained a class of publicly traded securities registered with the SEC and traded on the New York Stock Exchange.

According to the documents in this case, between at least 2006 and 2015, Deutsche Bank provided valuable employment to the relatives of foreign government officials in at least China and Russia as a personal benefit to the officials in order to obtain or retain business in those countries. These improper hires were made despite Deutsche Bank's recognition that hiring the relatives of foreign government officials and other clients in exchange for business could violate the FCPA and other anti-bribery laws, and in 2010, Deutsche Bank enacted a written hiring policy in the Asia-Pacific region (“APAC”) to detect and prevent certain corrupt hiring practices. However, this hiring policy was not effectively enforced and did not apply to all categories of hires. Deutsche Bank employees created false books and records that concealed corrupt hiring practices and failed to accurately document and record certain related expenses and Deutsche Bank failed to devise and maintain a system of internal accounting controls around its hiring practices sufficient to provide reasonable assurances that its employees did not bribe foreign government officials.

In a settled administrative proceeding on August 22, 2019, the SEC ordered Deutsche Bank to cease and desist violations of the books and records and internal controls provisions of the FCPA. Under the terms of the settlement, Deutsche Bank also agreed to pay disgorgement of $10,785,900, prejudgment interest of $2,392,950, and a civil money penalty in the amount of $3,000,000. The SEC noted Deutsche Bank's cooperation and remediation in its determination not to impose a larger civil fine against the company.

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