Reputational risk at heart of SAR report filed by Deutsche Bank officials in U.S.


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Deutsche Bank employees reported their employer for suspicious transaction related to sale of U.S. real estate to Russian oligarch family

Deutsche Bank officials in a U.S. branch filed a Suspicious Activity Report on their own employer last year. The SAR was filed in regard to a Deutsche Bank transaction to sell their stake in a California office building for $72 million to the son of a Russian oligarch. While the filing of SARs is a common occurrence, it’s rare for a bank to file on its own transaction.

According a New York Times report, the U.S.-based Deutsche Bank officials expressed concern to bank leaders that engaging in that transaction while under various investigations for money laundering for wealthy Russians was concerning. The U.S.-based employees did not appear to believe the transaction was illegal but that it was concerning in terms of reputation given the scope and magnitude of the bank’s ongoing entanglement with AML investigations tied to Russia.

When the home office in Frankfurt went ahead with the sale, U.S.-based employees decided to file the SAR with U.S. FinCEN officials. This move occurred after New York-based executives unsuccessfully urged their employer to block the transaction, a decision that was overruled by bank executives in Europe, according to sources for the Times.

A bank spokesman cited in the article made clear that while there may have been reputational risk, Deutsche Bank was certain that the transaction did not violate any AML laws or sanctions.

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