Co-Founder Ray D. McKenzie spoke with Law360 regarding the $150 million fine recently imposed on Deutsche Bank AG by the New York Department of Financial Services (“DFS”) for alleged failures in its anti-money-laundering compliance program. DFS’s allegations focused on Deutsche Bank’s relationship with convicted sex offender Jeffrey Epstein and two correspondent banks, Danske Bank Estonia and FBME Bank. McKenzie opined that the fine imposed on Deutsche Bank serves as a warning to other financial institutions that they should have compliance programs in place that recognize the risk of dealing with particular clients and should take appropriate corrective action when those programs identify red flags.
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