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16 Nov 2023

Deutsche Bank's response (to No Business With Genocide - Action Network)

16 November 2023

Thank you for your public letter, in which you have asked us to provide you with information on our compliance regarding Myanmar financial institutions and our internal policy regarding the risk of sanctions evasion.

Deutsche Bank does not maintain business relationships with Myanmar banks sanctioned by the UN, EU, U.S., UK or any entity owned by any sanctioned Myanmar entity. Deutsche Bank also has no branches, subsidiaries, or affiliates located, organized, or operating in Myanmar.

Deutsche Bank is firmly committed to compliance with all applicable sanctions laws and regulations, including but not limited to those administered and enforced by the EU and its Member States and the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) as well as the sanctions regimes of any other country in which Deutsche Bank conducts business.

Deutsche Bank has implemented policies and procedures which are reasonably designed to comply with applicable sanctions laws and regulations. As part of our Sanctions Compliance Program, we have, where applicable, procedures in place to screen customers and other parties, as well as transactions, aimed at ensuring that all business activity involving Deutsche Bank is compliant with applicable sanctions laws and regulations.

These procedures include, but are not limited to, all relevant business activity involving Deutsche Bank, screening against the most up-to-date versions of the following lists, among others, where applicable:

  • The United Nations Security Council Sanctions Lists
  • The Consolidated List of EU Financial Sanctions
  • Lists maintained by the U.S. Department of the Treasury’s OFAC; and
  • HM Treasury’s Consolidated List of Financial Sanctions Targets.

The screening includes all entities or individuals sanctioned in Myanmar, including the banks to which you have referred as well as those owned by the sanctioned entities.

If clients become the target of applicable sanctions, their respective accounts will be blocked, frozen or left to lie dormant, depending on which regulations are applicable and the legal obligations under such regulations.

All applicable sanctions lists are used as part of Deutsche Bank's screening and filtering processes. Regular KYC, including sanctions-related screening, is carried out for all clients when on-boarded. Furthermore, Deutsche Bank conducts regular reviews of its existing clients utilizing a risk-based approach including the use of sanctions-related screening and further checks upon the imposition of new sanctions. In addition, Deutsche Bank conducts real-time transaction filtering.

Besides taking steps to ensure compliance with the sanctions imposed by the UN, EU and US, Deutsche Bank continues to have an internal policy in place aimed at restricting business with Myanmar.

Deutsche Bank continues to monitor the situation in Myanmar closely, including information and reports related to human rights abuses. This also comprises monitoring of relevant legal developments in relation to the country such as applicable sanctions laws and regulations. Deutsche Bank is firmly committed to respecting human rights and has been a member of the United Nations’ Global Compact for more than 20 years. Its framework endorses international standards, such as the United Nations’ Guiding Principles on Business and Human Rights. Thus, our institution has the goal to play a vital role in aligning strategies and operations with universal principles of human rights and in helping to prevent apparent human rights abuses. Information on Deutsche Bank’s approach to uphold its responsibility to respect human rights is published on our website.