In 2013, Danske Bank was made aware of potential money laundering through its branch in Estonia. The whistleblower report suggested that the bank was being used by Putin’s family and a group of accused money launderers to launder funds, and that the Russian Intelligence Service, the FSB, was also using it for the same purpose. The report highlighted a near total failure of the bank’s AML controls, and suggested that the bank may have committed a criminal offence. This highlights deficiencies in Danske Bank well beyond a compliance issue, and instead suggests potential complicity in the activity by one or more employees at the branch. While AML/CFT norms and regimes are by no means fool proof, the easiest way around them is often to have a helpful insider, something that is almost certainly required for this scale of illicit financing.

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Compliance, espionage financing, illicit financing


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