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TRANSCRIPT
Welcome to our press conference
19 September 2018
2
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Participants
Ole Andersen,
Chairman of the Board of Directors of Danske Bank
Carol Sergeant,
Vice Chairman of the Board of Directors of Danske Bank
Ole Spiermann,
Partner at the Bruun & Hjejle law firm
Jørn P. Jensen,
Member of the Board of Directors of Danske Bank and
Chairman of the Audit Committee
Thomas F. Borgen,
CEO of Danske Bank
3
Danske Bank has not
lived up to its
responsibility
We take the combating
of money laundering
and financial crime
very seriously
The case in no way
reflects the bank we
want to be
4
The firstwarnings cameback 2007
Inadequate AML procedures in Estonia
The problems were much largerthan originallyassumed
Lack of management in Estonia and at Group level
The investigations conclude that
5
The investigations have had consequences
Research, training, projects and other initiatives aimed at
combating financial crime
42 reports to the authorities
8 reports to the police
Reporting to authorities
Warnings
Dismissals
Loss of bonus payments
Staff-related
consequences
Donation
6
Reflections of the Board of Directors
1
2
3
Great caution when making acquisitions outside core markets
Focus on integration and effective implementationof controls and systems
Cultural integration is decisive for transparency and trust
Governance of the investigationCarol Sergeant, Vice Chairman of Danske Bank’s Board of Directors
8
• Text 1
The investigation
Comprehensive and objective investigations led by the Bruun & Hjejle law firm
What exactly
happened at the
branch in Estonia
Around 70 persons
have worked full-time
on the investigations
Wish for objective and
complete investigations
9
Two overall tracks of investigation
Investigation of the
non-resident portfolioInvestigation of accountability
• 15,000 customers
• 9.5 million payments
• Internal collusion
• Institutional and individualaccountability
• 12,000 documents
• 8 million e-mails
Non-Resident Portfolio at Danske Bank’s Estonian branch, 2007-20171 9 S E P T E M B E R 2 0 1 8
Flow of the customers of the Non-Resident Portfolio
11
Development of the Non-Resident Portfolio
12
0
500
1.000
1.500
2.000
2.500
3.000
3.500
4.000
4.500
2007 2008 2009 2010 2011 2012 2013 2014 2015
CORPORATE ENTITIES PRIVATE PERSONS TOTAL
Inadequate AML procedures at the Estonian branch
13
Obligations AML failings re Non-Resident Portfolio at the Estonian branch
Due diligence
Lacking knowledge of customers
Lacking identification of (ultimate) beneficial owners and “controlling interests”
Customers included so-called intermediaries, which were unregulated and represented unknown end-customers
Monitoring
Insufficient attention to customer activities
Lacking identification of the source and origin of funds
No screening of customers against lists of politically exposed persons
No screening of incoming payments against sanctions or terror lists
In general, no automatic screening of incoming payments
Reporting Lack of response to suspicious customers and transactions
Sources and participants – customers, transactions and potential internal collusion
14
Sources
Information on customers
Approx. 10 mill. payments
Other material
CIM TEAM
Sources and participants – course of events and accountability
15
Sources
More than 8 million emails
and attachments
Review of more than 12,000
documents, including 4,000
emails
74 interviews with 49
persons
Deposits for non-resident customers in Baltic banks
16
0
2
4
6
8
10
12
14
16
2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
DEPOSITS OF THE NON-RESIDENT PORTFOLIO IN THE ESTONIAN BRANCH
TOTAL DEPOSITS OF NON-RESIDENTS IN ESTONIA
TOTAL DEPOSITS OF NON-RESIDENTS IN THE BALTICS
EU
RB
ILL
ION
The Non-Resident Portfolio – and other customers subject to investigation
17
15,000 non-resident customers pursuant to broader definition
10,000 customers in the Non-Resident Portfolio
Geographical distribution of the Non-Resident Portfolio
18
Applied model of analysis
19
Geographical distribution of flow of the Non-Resident Portfolio
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Incoming funds Outgoing funds
Customers in the Non-Resident
Portfolio
Estonia (23 %)
Russia (23 %)
Latvia (12 %)
Cyprus (9 %)
UK (4 %)
Other (30 %)
Estonia (15 %)
Latvia (14 %)
China (7 %)
Switzerland (6%)
Turkey (6 %)
Others (52 %)
Historical SARs and inquiries from the Estonian FIU
21
Suspicious non-resident customers
Approximately 6,200 customers deemed suspicious
22
Key events from 2007 to 2014
23
Inquiries from the DFSA to Group in 2012 and 2013
Meeting with the EFSA i 2013
Termination of correspondent banking relationship in 2013
Business review of the Non-Resident Portfolio in 2013
Whistleblower report at the end of 2013
Acquisition of SampoPank
Critical inspection report by EFSA
Letter from the Russian Central Bank
No integration of IT-platform for Group and the Baltics in 2008
EFSA inspection report in 2009
Reassuring reporting from Group Internal Audit and Group Compliance & AML
2007 2008-2012 H1 2014
Group Internal Audit reports in January and February
Working group established
Customer review of the Non-Resident Portfolio
2012-2013
Reponses to whistleblower and GIA reports in 2014
24
Reporting to FSAs
Whistleblower allegations
Customer review
HR action
Identified AML risk
Responsibility for reporting is unclear
Reporting to neither the Danish FSA nor the Estonian FSA takes place
Responsibility for investigation into allegations is unclear
Insufficient investigation of allegations takes place
Customer review is organised and executed inadequately
No action against branch management
No effective response to the identified AML risk
No ”look back”
Key events from 2014 to 2017
25
New policy regarding the Non-Resident Portfolio
Strategy discussions regarding the Baltics at both the Executive Board and the Board of Directors
New, highly critical EFSA inspection report
H2 2014 2015 2017
“Russian Laundromat”
Promontory’s root-cause analysis
“Azerbaijani Laundromat”
Extended investigations
Highly critical inspection report from the DFSA with reprimand
2016
Termination of correspondent banking relationships
Final precept by EFSA with orders
Termination of the Non-Resident Portfolio
Termination of the Non-Resident Portfolio
26
Note: Historical graph reported by Danske Bank in 2017.
Standards of accountability
27
Employment contracts and employment law
The duties of members of Board as found in statutory law and internal procedures
Fitness and propriety
Civil liability (tort)
Criminal liability
Involved persons and departments
28
Baltic Banking/ International Banking
Executive Board
CEO
Board of Directors / Audit Committee
Estonian branch
Danske Bank’s compliance and AML workJørn P. Jensen, Member of the Board of Directors of Danske Bank and Chairman of the Audit Committee
30
We have taken a number of initiatives to address the problems in Estonia
The portfolio of non-resident customers wasclosed down by the end of 2015
New management across the Baltic countries
Independence of local control functions has beenstrengthened
The Baltic units have been transferred to the joint IT platform
In future, we will serve only subsidiaries of Nordic and international customers
31
Initiatives to improve general efforts across the Group
1
2
3
Stronger compliance culture and more knowledge
Investments in more employee resources, new IT systems and stronger competencies
Stronger organisation and internal procedures
32
In coming years, we will continue to improve our
efforts to combat financial crime
33
Ongoing implementation of orders from the Danish FSA
New Chief Compliance
Officer to take up office
Group assessment of
management and
governance at the
branch in Estonia
New initiatives and
procedures to ensure
prompt investigation and
escalation of issues
Implementation of
Pillar II capital add-on
Integration of compliance
as a fundamental part of
the culture
Central unit at Group level to
ensure transparency and
completeness in our interaction
with the Danish FSA
34
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Disclaimer
Important Notice
This presentation reproduces statements from Bruun & Hjejle’s Report on the Non-Resident Portfolio at Danske Bank’s Estonian branch, dated 19 September 2018, to which we refer. In the event of any discrepancy or ambiguity, the report from Bruun & Hjejle takes precedence.
This presentation does not constitute or form part of and should not be construed as, an offer to sell or issue or the solicitation of an offer to buy or acquire securities of Danske Bank A/S in any jurisdiction, including the United States, or an inducement to enter into investment activity. No part of this presentation, nor the fact of its distribution, should form the basis of, or be relied on in connection with, any contract or commitment or investment decision whatsoever.
This presentation contains forward-looking statements that reflect management’s current views with respect to certain future events and potential financial performance. Although Danske Bank believes that the expectations reflected in such forward-looking statements are reasonable, no assurance can be given that such expectations will prove to have been correct. Accordingly, results could differ materially from those set out in the forward-looking statements as a result of various factors many of which are beyond Danske Bank’s control.
This presentation does not imply that Danske Bank has undertaken to revise these forward-looking statements, beyond what is required by applicable law or applicable stock exchange regulations if and when circumstances arise that will lead to changes compared to the date when these statements were provided.