Compliance Lessons From Danske Bank’s $2b Fraud Guilty Plea
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Compliance Lessons From Danske Bank’s $2b Fraud Guilty Plea

Author, Washington Legal Foundation, Dec. 19, 2022

On December 13, Denmark-based multinational banking and financial services company, Danske Bank A/S, pleaded guilty in U.S. District Court to one count of conspiracy to commit bank fraud and agreed to forfeit more than $2 billion1 to resolve a long-running investigation into its relationships with certain U.S. banks.  Dansk Bank admitted to defrauding these banks by misrepresenting the details of one of its business unit’s anti-money laundering (“AML”) compliance program.  In announcing the resolution, Deputy Attorney General Lisa Monaco emphasized that DOJ “expects companies to invest in robust compliance programs—including at newly acquired or far-flung subsidiaries—and to step up and own up to misconduct when it occurs.”  The detailed statement of facts that accompanied the plea agreement suggests several potential lessons for corporate compliance efforts.

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