Deutsche Bank AG (“DB AG”), DB USA Corporation and Deutsche Bank AG New York Branch (collectively, “DB”) agreed to pay an aggregate fine of US $136.95 million pursuant to a consent order initiated by the Board of Governors of the Federal Reserve System for failing to have an “effective and comprehensive risk management framework” related to its foreign exchange trading activities from October 2008 through October 2013. During that time, claimed the FRB, DB traders engaged in communications with traders from other financial institutions through electronic chat rooms where they disclosed trading positions and coordinated trading strategies; discussed possible FX-benchmark price fixing; discussed bid/offer spreads offered to FX customers; and discussed trading overall in a manner to benefit DB’s trading positions. In addition to agreeing to pay a fine, DB consented to other undertakings, including, within 90 days, to submit a plan to improve DB’s compliance with applicable laws and regulations in connection with its FX trading, as well as its trading of commodities and interest rate products. In May 2015, five major international banks, not including DB, pleaded guilty to conspiring to manipulate the price of certain foreign exchange transactions, and agreed to pay fines totaling US $5.6 billion, as well as other sanctions, to resolve criminal proceedings by the US Department of Justice and disciplinary proceedings by other US regulators. (Click here for details, in the article “Five Banks Plead Guilty to Forex Manipulation Activities and Agree to Fines Totaling US $5.6 Billion and Other Sanctions” in the May 31, 2015 edition of Bridging the Week.) Separately, DB also entered into a consent order with the FRB for not, since July 21, 2015, establishing a compliance program “reasonably designed” to ensure and monitor compliance with certain of its obligations regarding proprietary activities under the Dodd Frank Wall Street Reform and Consumer Protection Act and certain related rules enacted by the FRB (collectively, the “Volcker Rule”). Under this consent decree, DB agreed to pay a fine of US $19.71 million and agree to additional undertakings.