We ensure compliance with laws and regulations with the aid of special programs and structures:
- Anti-Financial Crime Committee (AFCC) Group-wide oversight and governance body aimed at curbing financial crime
- Anti-money laundering program
- Anti-corruption Guideline: System of rules for combating corruption and bribery
- Global Compliance Core Principles: Set of principles that commits the employees and senior managers to uphold principles of integrity, accountability, responsibility, fairness and considerateness
- Know-Your-Customer (KYC) Policy: System of rules for the KYC process, i.e. scrutiny of clients that is mandatory for banks in order to combat money laundering
- Compliance Control Framework
- Red Flags Monitoring Process: A process that enables the reporting of risk-related breaches. The results of the monitoring are taken into account into year-end performance assessments
- Regulatory Contact Offices: Offices of Deutsche Bank in Frankfurt am Main, London and New York that manage contacts and communication with domestic and foreign supervisory authorities
Employees with completed compliance trainings
Proportion of total employees in %
During 2012, over 125 new and updated training courses were rolled out to staff globally, resulting in over 255,000 completed training assignments. During 2012, the number of staff with overdue training was consistently below 8% of the global headcount. Key 2012 and 2013 courses addressing ethics and integrity issues include: Compliance Essentials, Anti-Money Laundering, Risk Culture, Supervision, Code of Business Conduct and Ethics, Tone at the Top, and Market Conduct.
The fall in employees with completed compliance trainings results from an update of the Private and Business Clients Webbased training on Compliance Essentials in 2012. This training is rolled out every second year. The updated training will be rolled out globally in the second half of 2013.