SEC Charges Deutsche Bank With FCPA Violations Related to Third-Party Intermediaries
summary
The Securities and Exchange Commission charged Deutsche Bank AG with violating the Foreign Corrupt Practices Act (FCPA) by using third-party intermediaries to bribe foreign officials and their associa
paragraph
The Securities and Exchange Commission charged Deutsche Bank AG with violating the Foreign Corrupt Practices Act (FCPA) by using third-party intermediaries to bribe foreign officials and their associates to secure global business. The SEC found that the bank lacked sufficient internal accounting controls, resulting in approximately $7 million in improper payments that were falsely recorded as legitimate business expenses through falsified documentation. To resolve the charges, Deutsche Bank agreed to a cease-and-desist order and a settlement of over $43 million to the SEC, which included $35 million in disgorgement and $8 million in prejudgment interest. This SEC action was part of a coordinated resolution with the Department of Justice that included a separate $79 million criminal penalty.
Classified fcpa(confidence 100%). No EDGAR filing fingerprint (criminal/DOJ-side scheme). detection rule →
Parties
$43 million to settle sec chargesdaniel wadleydeutsche bank agdeutsche bank employeesfcpa unit investigationSecurities and Exchange Commission
Keywords
deutsche bankdeutschebanksecmillionthird-party intermediariesinternal accountingaccounting controlsfcpaorderintermediariesbusinessbank fcpafcpa relatedrelated third-party
Exhibits & Attached Documents (1)
Extracted insights
Dollar amounts 6
- $120.00M $120 million $100M–$1B
- $79.00M $79 million $10M–$100M
- $43.00M $43 million $10M–$100M
- $35.00M $35 million $10M–$100M
- $8.00M $8 million $1M–$10M
- $7.00M $7 million $1M–$10M
Entities 6
- agency $43 million to settle sec charges
- person daniel wadley
- person deutsche bank ag
- person deutsche bank employees
- person fcpa unit investigation
- agency Securities and Exchange Commission
Triples 13
- Securities and Exchange Commission announced charges against Deutsche Bank AG for violations of the Foreign Corrupt Practices Act
- Deutsche Bank AG agreed to pay $120 million
- Deutsche Bank AG agreed to pay $43 million to settle SEC charges
- Deutsche Bank AG engaged foreign officials, their relatives, and associates as third-party intermediaries
- Deutsche Bank AG lacked sufficient internal accounting controls related to intermediary payments
- Deutsche Bank AG made approximately $7 million in bribe payments
- Deutsche Bank employees falsified invoices and documentation
- Deutsche Bank AG violated books and records and internal accounting controls provisions of the Securities Exchange Act of 1934
- Deutsche Bank AG agreed to cease-and-desist order
- Deutsche Bank AG agreed to pay $35 million disgorgement with $8 million prejudgment interest
- SEC did not impose civil penalty in light of $79 million criminal penalty
- Jennifer Moore and Tanya Beard conducted investigation in Salt Lake Regional Office
- Daniel Wadley supervised FCPA Unit investigation
PDF (from attached: pdf)
Text layers
Extracted body text (1,898c)
The Securities and Exchange Commission today announced charges against Deutsche Bank AG for violations of the Foreign Corrupt Practices Act (FCPA). As part of coordinated resolutions with the SEC and the Department of Justice, Deutsche Bank has agreed to pay more than $120 million, which includes more than $43 million to settle the SEC’s charges. According to the SEC’s order, Deutsche Bank engaged foreign officials, their relatives, and their associates as third-party intermediaries, business development consultants, and finders to obtain and retain global business. The order finds that Deutsche Bank lacked sufficient internal accounting controls related to the use and payment of such intermediaries, resulting in approximately $7 million in bribe payments or payments for unknown, undocumented, or unauthorized services. The order further finds that these payments were inaccurately recorded as legitimate business expenses and involved invoices and documentation falsified by Deutsche Bank employees. “While third parties can assist in legitimate business development activities, it is critical that companies have sufficient internal accounting controls in place to prevent payments to third parties in furtherance of improper purposes,” said Charles Cain, Chief of the SEC Enforcement Division’s FCPA Unit. The SEC’s order finds that Deutsche Bank violated the books and records and internal accounting controls provisions of the Securities Exchange Act of 1934. Deutsche Bank agreed to a cease-and-desist order and to pay disgorgement of $35 million with prejudgment interest of $8 million to settle the action. The SEC did not impose a civil penalty in light of the $79 million criminal penalty paid in the criminal resolution. The investigation was conducted by Jennifer Moore and Tanya Beard of the FCPA Unit in the Salt Lake Regional Office under the supervision of Daniel Wadley.
OCR text (1,898c · html-text · 99% conf)
The Securities and Exchange Commission today announced charges against Deutsche Bank AG for violations of the Foreign Corrupt Practices Act (FCPA). As part of coordinated resolutions with the SEC and the Department of Justice, Deutsche Bank has agreed to pay more than $120 million, which includes more than $43 million to settle the SEC’s charges. According to the SEC’s order, Deutsche Bank engaged foreign officials, their relatives, and their associates as third-party intermediaries, business development consultants, and finders to obtain and retain global business. The order finds that Deutsche Bank lacked sufficient internal accounting controls related to the use and payment of such intermediaries, resulting in approximately $7 million in bribe payments or payments for unknown, undocumented, or unauthorized services. The order further finds that these payments were inaccurately recorded as legitimate business expenses and involved invoices and documentation falsified by Deutsche Bank employees. “While third parties can assist in legitimate business development activities, it is critical that companies have sufficient internal accounting controls in place to prevent payments to third parties in furtherance of improper purposes,” said Charles Cain, Chief of the SEC Enforcement Division’s FCPA Unit. The SEC’s order finds that Deutsche Bank violated the books and records and internal accounting controls provisions of the Securities Exchange Act of 1934. Deutsche Bank agreed to a cease-and-desist order and to pay disgorgement of $35 million with prejudgment interest of $8 million to settle the action. The SEC did not impose a civil penalty in light of the $79 million criminal penalty paid in the criminal resolution. The investigation was conducted by Jennifer Moore and Tanya Beard of the FCPA Unit in the Salt Lake Regional Office under the supervision of Daniel Wadley.