Paul Steiner

Spotlight Powered by - AML Penalties Commerzbank AG is a global German universal bank headquartered at Commerzbank Tower in Frankfurt. The bank was founded in Hamburg in 1870 and is today among the largest credit institutions in Germany. The Federal Financial Supervisory Authority - BaFin has imposed a fine of USD 1,545,076 (EUR 1.45 Mn) on Commerzbank AG for breaching its anti-money laundering (AML) laws. The bank did not update customer data on time and did not provide proper security measures, which resulted in inadequate due diligence in three cases, thus violating its anti-money laundering obligations. To read more, please click: https://zurl.co/VFLw Subscribe to AML Penalties @ https://zurl.co/343z for more insights & updates. Visit our website: https://zurl.co/PWxy #antimoneylaundering #amlpenalties #aml #financialcrimes #moneylaundering #amlcompliancefailure #compliancefailure #bafin #germany #commerzbank #amlviolations #breach #law

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𝗕𝗿𝗲𝗮𝗸𝗶𝗻𝗴 𝗡𝗲𝘄𝘀: 𝗧𝗵𝗲 𝗚𝗲𝗿𝗺𝗮𝗻 𝗳𝗶𝗻𝗮𝗻𝗰𝗶𝗮𝗹 𝘄𝗮𝘁𝗰𝗵𝗱𝗼𝗴 𝗕𝗮𝗙𝗶𝗻 𝗵𝗮𝘀 𝗼𝗿𝗱𝗲𝗿𝗲𝗱 𝗖𝗼𝗺𝗺𝗲𝗿𝘇𝗯𝗮𝗻𝗸 𝘁𝗼 𝗽𝗮𝘆 𝗮 𝗳𝗶𝗻𝗲 𝗼𝗳 𝟭.𝟰𝟱 𝗺𝗶𝗹𝗹𝗶𝗼𝗻 𝗲𝘂𝗿𝗼𝘀 (£𝟭.𝟮𝟱 𝗺𝗶𝗹𝗹𝗶𝗼𝗻) 𝗳𝗼𝗿 𝗯𝗿𝗲𝗮𝗰𝗵𝗶𝗻𝗴 𝗶𝘁𝘀 𝗮𝗻𝘁𝗶-𝗺𝗼𝗻𝗲𝘆 𝗹𝗮𝘂𝗻𝗱𝗲𝗿𝗶𝗻𝗴 𝗱𝘂𝘁𝗶𝗲𝘀, 𝗮𝘀 𝗮𝗻𝗻𝗼𝘂𝗻𝗰𝗲𝗱 𝗼𝗻 𝗠𝗼𝗻𝗱𝗮𝘆. According to BaFin's statement, both Commerzbank AG and the former comdirect Bank AG failed to fulfil their supervisory duties, particularly regarding timely customer data updates and proper security measures. These lapses resulted in inadequate due diligence in three cases, thus violating anti-money laundering obligations. In response, Commerzbank stated that it has revised its due diligence processes and updated customer data following the comdirect acquisition. "Processes were adjusted accordingly, and the data updates were completed in full in 2022," the bank added, emphasising compliance with BaFin's requirements. This development underscores the significance of stringent anti-money laundering measures in the banking sector, highlighting ongoing efforts to strengthen regulatory compliance. 𝗙𝗼𝗹𝗹𝗼𝘄 Hartford Consulting Ltd 𝘁𝗼 𝗸𝗲𝗲𝗽 𝘂𝗽 𝗱𝗮𝘁𝗲𝗱 𝘄𝗶𝘁𝗵 𝘁𝗵𝗲 𝗹𝗮𝘁𝗲𝘀𝘁 𝗿𝗲𝗴𝘂𝗹𝗮𝘁𝗼𝗿𝘆 𝘂𝗽𝗱𝗮𝘁𝗲𝘀 𝗮𝗻𝗱 𝗳𝗼𝗿 𝗺𝗼𝗿𝗲 𝗙𝗶𝗻𝗮𝗻𝗰𝗶𝗮𝗹 𝗖𝗿𝗶𝗺𝗲 𝗻𝗲𝘄𝘀. #BaFin #Commerzbank #AntiMoneyLaundering #AML #FinancialRegulation #Banking #Compliance #RegulatoryCompliance #Hartfordconsultants

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The importance of Anti-Money Laundering (AML) in the banking industry is undeniable, especially with the increasing prevalence of online transactions and the need for faster payment processing. This underscores the growing significance of AML and its role in shaping the future of banking operations. This fine from the regulatory authority shows that errors in this area can be rather costly.

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Big shift in the digital payments landscape as EPI arriving! 💳🚀 German banks are discontinuing Giropay (founded in 2015 by Commerzbank, Deutsche Bank, and others to fight PayPal) and shifting focus to the European Payment Initiative's new wallet, "Wero." 💼💶 Set to launch in late June, Wero aims to rival PayPal and other giants in online transactions. 🌐📱 With enhanced security features 🔒, seamless integration 🔗, and a unified European approach 🌍, Wero is poised to revolutionize the market. Is this the dawn of a new era in European digital payments? 💼💶 Read more about this strategic pivot and what it means for the market: https://lnkd.in/duJCywSK #FinTech #DigitalPayments #EPI #Wero #BankingInnovation #DeutscheBank #CommerzBank #PayPal #Giropay

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In the last two weeks, two European financial giants 🏦 have been fined by regulators for breaching their anti-money laundering obligations. 1️⃣ Germany's financial watchdog BaFin has fined Commerzbank €1.45m for failing to comply with its AML/CFT obligations. 📌 According to the BaFin, Commerzbank AG and the former Comdirect Bank AG, of which Commerzbank AG is the universal successor, breached their regulatory obligations. In other words, the bank did not update customer data in a timely manner and did not take adequate security measures, resulting in insufficient due diligence in three cases. 2️⃣ Autorité de contrôle prudentiel et de résolution (ACPR), the French sanctions commission, has fined Treezor, a subsidiary of Société Générale, €1m for "very serious shortcomings" in the fight against ML and TF. 📌 Acquired by Société Générale in 2019, Treezor is one of the first companies in France to implement the Banking-as-a-service (BaaS) model, offering white-labeled payment services to its clients, mainly fintechs, banking and insurance startups. There were "very serious breaches" which "seriously undermined several fundamental elements of the system for combating ML/TF". At the time of the inspection, Treezor had not established a risk profile for its business relationships that would allow it to "meet its obligation of constant vigilance" and its system for monitoring its operations was "inadequate in many respects", the decision said. In these two cases, the findings of the German and French supervisors on these two FIs are quite different, but we can still see some similarities. ⚖ 💡 In the case of Commerzbank, the problem seems to stem from a mismatch between the change in the actual risk level of part of their customer portfolio and the timing of their review and update in their systems. This is a problem that we see regularly and have addressed with one of our new features, dynamic risk scoring, which provides a constant view of changes in customer risk levels, even between two ODD reviews. 💡 And as far as Treezor is concerned, we intuitively suspect that the problem also stems from a lack of sufficient knowledge of their end users in their BaaS model. We have also dealt with this recurring situation (Railrs, ModulR, Solaris, etc.) and created our multi-layer transaction monitoring feature specifically for this purpose. Interested in how you can increase the efficiency of your CDD processes while mitigating your regulatory risk? Get in touch 😉   #AML #CFT #AMLpenalties #DynamicRiskScoring #BaaS

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LATEST: Germany's Commerzbank AG has been fined €1.45M for #AML failings at a subsidiary, regulator BaFin announced today (Mon). We report. Also today, in Britian the Financial Conduct Authority's plans to 'name and shame' banks more often and at the outset of inquiries are set for the scrapheap. The proposals have met an unprecedented backlash from #government, #banks and #lawyers. The 'name and shame' plan was outlined amidst much fanfare in February in the FCA's new 'bad cop, bad cop' approach to regulation. But as the City of London warned the regulator was driving financial institutions out of Britain, the plan is set for the sidings. We report. #followthemoney #aml #cft #compliance #banks #banking #fintech #finreg #regtech #FCC Stephen Rae James Treacy Alisha H. https://lnkd.in/egqYJp-D

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New task force in Baden-Württemberg in the fight against money laundering... A lot is happening in the fight against money laundering, which continues to be a huge problem for Germany as a business and financial centre. Parallel to the implementation of the government's so-called Financial Crime Prevention Act, individual federal states are apparently also upgrading their defences in the fight against gold laundering. A new team of specialists is to ensure more efficient prosecution in Baden-Württemberg. According to a corresponding cabinet bill, specialists from the police, tax investigation department and public prosecutor's offices are to work closely together in the planned interdepartmental investigation unit in order to make the investigation work more effective and efficient. The task of the new special unit will be to process significant cases of money laundering and related predicate offences as well as tax offences and the early filtering of transactions that indicate terrorist financing. In view of the explosive nature of the topic and the continuing increase in the number of reports of suspected money laundering, the workload of the special unit will be very high. Just covering the personnel requirements, which will also be very high, will be demanding. This is all the more true as the new authority, which will be equipped with all the powers of the criminal prosecution authorities under the Financial Crime Prevention Act, will also have high staffing requirements in significant international cases involving Germany. The concept of starting with suspicious financial flows in order to uncover the underlying criminal offences and professional backers and networks ("follow the money") is correct and important, even if the prosecution process will not be easy at times.

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🌟 UPDATE: EU Legislative Changes Impacting Swiss and German Banking Sectors 🌟 🔔 Introduction of Mandatory Branch Requirement Recent legislative changes at the EU level have introduced a mandatory branch requirement for the provision of core banking services by third-country banks. This development will significantly impact the Swiss and German banking sectors. 🏦 Impact on Swiss Institutions Swiss institutions currently exempt from the licensing requirement under Section 2 (5) of the German Banking Act (KWG) or those with a simplified exemption may no longer be authorised to actively provide or distribute services in Germany once the Capital Requirements Directive VI is implemented. 🔍 Need for Vigilance and Legal Analysis It's crucial to closely monitor the further implementation of these changes at the national level. Swiss banks serving the German market under a standard or simplified exemption should consider the implications of the new directive promptly and conduct a thorough legal analysis of their situation. 📅 Timeline for Implementation The Directive has not yet been published in the Official Journal, but publication is expected soon. Direct application at the national level in individual Member States is anticipated to begin from the end of 2026 or the beginning of 2027. 💼 Stay Informed and Prepared As these changes unfold, staying informed and prepared will be key for financial institutions navigating this evolving landscape. Engage with legal experts, assess your strategies, and ensure your compliance to remain competitive.

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The National Association of German Cooperative Banks (BVR) and the German Savings Banks Association (DSGV) are calling on the European Parliament’s ECON Committee to take the vote on the European Deposit Insurance Scheme (EDIS) off the agenda. At least until the current review of the Crisis Management and Deposit Insurance (#CMDI) framework is concluded. There is no comprehensible reason to hurry the ECON vote on EDIS. Instead, EU policymakers should focus on earning trust and ensure stability, particularly in a European election year. A hurried EDIS is a gift for populists in the election. Bearing in mind the major challenges we currently face, a balanced and sustainable plan is necessary to secure rather than jeopardise the future success of the Banking Union and the Capital Market Union. The National Association of German Cooperative Banks (BVR) and the German Savings Banks Association (DSGV) are taking proactive steps to address this challenge in connection with the current review of the Crisis Management and Deposit Insurance (CMDI) framework. OnePager: https://lnkd.in/d8xgZ8Y4

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German regulator BaFin has fined N26 9.2 million Euros for delayed filing of anti-money laundering reports in 2022. German regulator reportedly stated that credit institutions are obliged to report to financial intelligence units, if the y suspect that transaction could be due to #moneylaundering and #terroristfinancing. It is required that reports should be submitted promptly so that authorities can take action. N26 reportedly has invested 80 million Euros to comply with highest standards in fighting money laundering. According to N26 press release The company had already allocated funds for a potential fine in its 2022 annual financial statements, and the actual fine is less than the amount reserved. This is not the first time N26 has been fined by BaFin. A few times back the fintech was ordered by regulator to put limit on customers growth as a risk mitigation measure. This required N26 to reduce the level of monthly customers to 50,000. What's next for N26? Will it continue to appropriate budget for non-compliance fines or work to mend its ways? A few months back Greg Coleshill while commenting on a history of N26's fines commented, "With any threat, there is often an opportunity and this could be a huge one for N26. Get things right, fix the problems, and create a platform for growth! 🚀" With Anti Money Laundering Authority being headquartered in Frankfurt, BaFin is likely to increase scrutiny of Germany's financial institutions. Thereofore, it may be high time for the obliged businesses to increase their #aml defenses. #Compliance #Fines #Germany #BaFin

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Preparation for #DORA application & Supervisory Expectations: ESAs publish templates and tools for voluntary dry run exercise to support the DORA implementation The European Supervisory Authorities (#EBA, #EIOPA and #ESMA – the ESAs) […] published [31/05/2024] #templates, technical #documents and #tools for the #dry #run exercise on the #reporting of registers of information in the context of Digital Operation Resilience Act (#DORA) announced in April 2024. (source: https://lnkd.in/ek287Cr8 ). The materials published […] include: templates for the registers of information with example (in Excel); draft technical package for reporting, including data point model (DPM),annotated table layout and validation rules; optional tool (VBA macro) to assist with the conversion of Excel templates into .csv files and .zip files for their submission; frequently asked questions regarding the exercise. All these materials are available on the dry run exercise webpage. #Financial #entities can use these materials and tools to prepare and report their registers of information of contractual arrangements on the use of ICT #third - #party #service #providers in the context of the dry run exercise, and to understand #supervisory #expectations for the reporting of such registers from 2025 onwards. […] Preparation for DORA application (including „ADDITIONAL DOCUMENTS“ and „TOOLS AND MATERIAL FOR DRY RUN“ (https://lnkd.in/egwhVnF9)) The #Digital #Operational #Resilience #Act (#DORA) will become applicable on 17 January 2025. From that date all financial entities in its scope will need to have a comprehensive #register of their contractual arrangements with ICT #third - #party service providers available at entity, sub-consolidated and consolidated levels. The registers will serve for: financial entities to monitor their ICT third-party risk, the EU competent authorities to supervise ICT and third-party risk management at the financial entities and the ESAs to designate the critical ICT third-party service provides (CTPP) which will be subject to an EU-level oversight. To help financial entities be ready with the preparation and submission of their registers of information from January 2025, the ESAs and competent authorities will carry out a dry run exercise on a best-efforts basis in 2024. […]

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Hig-level educational conference on #AML #banking #finance and also how new #tech like #AI and #blockchain are involved. With an #EU perspective.

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Few weeks ago, the European Banking Authority (EBA) has published its final Guidelines on the resubmission of historical data under the supervisory reporting framework. 🎯 The overall objective is to achieve more clarity, consistency and harmonisation when it comes to resubmissions of historical data after errors were detected in banks' comprehensive #COREP or #FINREP templates. Definitely a highly appreciated and long-awaited initiative! 👍 ⚠ However, the way to get there goes hand in hand with a set of new open questions and most likely the need for many banks to implement a standardised resubmission process that is able to reproduce high quality and consistent historical data over a long time horizon without paralysing the whole organisation. Reporting specialists know how painful this can be given the strong interconnectedness within EBA's Data Point Model... 💡 In our latest #regulatoryblog we outlined the key facts of the new EBA Guidelines and our view on potential impacts on banks' reporting practice. What are your thoughts on this? Feel free to contact us! 👏 Michael Schlembach Simon Blöchl Roman Seyfried https://lnkd.in/edJAVQwq

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#BaFin has levied a 1.4MM Euro fine against Commerzbank AG for inadequate monitoring of AML obligations. The Bank did not update customer #data on time or sufficiently and did not apply #EDD for three, high-risk clients. This enforcement touches on three hot regulatory topics: 1. Access to relevant and up-to-date data for critical compliance functions. 2. Risk mitigation of Politically Exposed Persons. 3. Risk-based customer due diligence to recognize shell companies and anonymous registration of companies. The Commerzbank action is similar to others from the FCA and the U.S. While for many years data requirements have followed an industry best practices model, regulators are more frequently addressing AML and Sanctions systems directly. For instance, EU regulations require #model #validators to have access to the data necessary to perform their duties, and #OFAC's FAQ 335 requires broker dealers to monitor for changes in value, volume and product among high-risk customers. A definition of good data quality to design your data program around is key to meeting regulatory expectations. A testing program that investigates the "dimensions" of data quality and issues stemming from within the firm and those originating from outside sources such as customers will help management understand whether their program's effectiveness is impacted by data quality. "Timely" and "accurate" are two dimensions of data quality that BaFin has highlighted here. https://lnkd.in/eeGTSS7w

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Ukrainian and German Financial Supervisory Authorities Expand Partnership "On 17 June, BaFin President Mark Branson and NSSMC НКЦПФР Chairman Ruslan Magomedov signed an institutional partnership agreement in Bonn. By doing so, the two supervisory authorities are expanding the cooperation they announced earlier this year." https://lnkd.in/gwffvKTu #fintech #finance #banking #paytech #payments #fintechnews #paymentsnews

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