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Private Banking Defences
For private bankers, preserving client wealth is a fundamental principle upon which they build their businesses and reputations. Preserving wealth against financial loss is one matter. Preventing financial loss or damage to clients from a financial crime event is another. For the latter, anti-money laundering (AML) training and other defences become a marketing tool, not a blockage created by the compliance function against new business.
In May 2019, the New York Times reported that staff at Deutsche Bank made internal reports on potential suspicious activity by entities related to the current US presidential administration. According to the newspaper, these internal alerts, known at many financial institutions as unusual transaction reports (UTRs), were ignored by senior management, yet no suspicious activity report (SAR) was lodged by the bank with the Financial Crimes Enforcement Network (FinCEN). The US House Financial Services Committee will undoubtedly issue subpoenas for these reports generated by Deutsche Bank staff. Unless UTRs are properly managed and protected by a financial institution, they may cause enormous headaches.