Jesper Berg's speaking notes from the Folketing's hearing on Danske Bank

The Danish Financial Supervisory Authority (Danish FSA) has published Jesper Berg's speaking notes for his presentation to the Folketing's hearing on Danske Bank of 19 November 2018. In particular, the purpose was to further communicate facts about the division of responsibility between Denmark and Estonia and about supervisory activities between 2007-2018.


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Translation from original text in Danish. In case of discrepancies, the Danish version prevails.

The presentation at the hearing highlighted that the Estonian FSA inspected Danske Bank's Anti Money Laundering (AML) setup in Estonia in 2007, 2009 and 2014. This emphasises the fact that AML supervision is the responsibility of the host country. This also follows from the EU rules and the joint statement issued by the Estonian FSA and the Danish FSA in May 2018.

The Estonian FSA presented a very critical report in 2014, which led to the closure of high-risk customer accounts at Danske Bank's Estonian branch. The Danish FSA was informed of the investigation by the Estonian authorities, as reflected in the Danish FSA’s subsequent report on the AML inspection at Danske Bank, published in March 2016.

On the other hand, the Estonian FSA’s observations on AML at Danske Bank's Estonian branch in 2007 were less critical, and in 2009, the observations were not critical.

The Estonian FSA has thus been responsible for and has conducted inspections at Danske Bank branch in Estonia regarding Estonian AML legislation, and the Estonian FSA has also been responsible for following up on these inspections. The Estonian FSA has shared its observations with the other supervisory authorities in the supervisory college of Danske Bank, headed by the Danish FSA in Denmark. 

The Danish FSA has performed AML inspections at Danske Bank in Denmark five times between 2010-2018, including a shorter inspection in 2012. In addition, the Danish FSA conducted a major governance investigation of Danske Bank in 2017-2018. The investigation concerned Danske Bank's management and control in relation to the Estonian branch. This investigation was not concerning AML legislation. 

See speaking notes (PDF)

See presentation (PDF)