Deutsche Bank AG agreed to pay sanctions of slightly more than GB £163 million (approximately US $203 million) to the UK Financial Conduct Authority and US $425 million to the New York State Department of Financial Services to resolve charges that it failed to follow applicable anti-money laundering requirements when it allowed unknown customers to use its Moscow, London and New York offices to move approximately US $1o billion from Russia to offshore bank accounts. The action brought by the NYS DFS also named Deutsche Bank’s New York branch. According to the NY DFS, between 2011 and early 2015, corporate clients of DB Russia on multiple occasions purchased Russian blue chip stocks, paying rubles, while shortly afterwards, a related entity (including a number of entities registered in Cyprus or the British Virgin Islands) sold the identical stock in London and was paid US dollars. However, claimed the FCA, the Moscow-side customers “had a number of high risk characteristics that were not categorized as high risk by Deutsche Bank” and insufficient information was obtained by the firm “to ensure that appropriate due diligence was performed” on London-side customers. As a result, said FCA, DB was not able to assess whether there were connections between the Moscow-side and London-side customers. This helped facilitate potential money laundering by the DB customers, charged the regulators. All the US dollar transactions flowed through Deutsche Bank Trust Company, a subsidiary of the bank’s NY branch, alleged the NYS DFS. Both FCA and the NYS DFS claimed that flaws in the bank’s know your customer policies and procedures, insufficient compliance and internal audit resources, lack of an automated AML system to detect suspicious trades, and a number of missed red flags, all contributed to the bank’s failure to timely detect the suspicious transactions. DB began an internal investigation of the suspicious trading in March 2015 and self-reported its initial findings to FCA and the NYS DFS. As part of its settlement with NYS DFS, DB also agreed to the appointment of an independent monitor to review its AML policies and procedures.