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On September 20, BuzzFeed News and the International Consortium of Investigative Journalists (ICIJ) published the FinCEN Files, a comprehensive investigation of global financial institutions involving “more than 400 reporters in 88 countries”. The FinCEN Files investigation purportedly “reveal[s] how some of the world’s biggest banks have facilitated the work of notorious terrorists, drug cartels, and despots” and centers around more than 2,100 suspicious activity reports (“SARs”) submitted to the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”). Banks and other financial institutions submit SARs when they observe transactions that suggest money laundering or other illegal activity, and while these reports can support investigations and intelligence gathering, they are not by themselves evidence of a crime. The FinCen Files included SARs filed by nearly 90 financial institutions.
One of the Buzzfeed articles published as a result of the FinCEN Files investigation states, among myriad other claims, that “Deutsche managers, including top executives, had direct knowledge for years of serious failings that left the bank vulnerable to money launderers. Documents show two warnings sent to committees that included Paul Achleitner, Deutsche’s chair, and one sent to the bank’s supervisory board.”
Deutsche Bank’s share price plummeted nearly 10% in intraday trading on September 21, 2020.