EFTA00151495

business with Western financial institutions until Cyprus' 2004 acceptance into the European 
Union. 
63. 
Due to Cypriot laws that placed restrictions on domestic financial institutions that 
primarily provided offshore banking services, FBME was incorporated in the Cayman Islands in 
1986, though it would remain headquartered and staffed in Cyprus. In 1987, FBME's Cyprus 
branch was granted a license by the Central Bank of Cyprus to assume banking activities within 
its jurisdiction. 
64. 
In April 2001, FBME's Cyprus branch opened a second account with DBTCA. 
65. 
After the September 11, 2001 terrorist attacks on the United States and in 
accordance with the USA PATRIOT Act, the Cayman Islands implemented legislation requiring 
all banks registered within the country to establish a physical local presence. In response, rather 
than complying with the new directive, FBME management elected to begin the process of 
relocating to Tanzania. In 2003 FBME was reincorporated in Tanzania, and also received a 
banking license from the Bank of Tanzania. 
66. 
Cyprus' acceptance to the European Union in May of 2004 precipitated the active 
correspondent banking relationship between FBME and Deutsche Bank. On August 23, 2004, 
FBME's Cyprus branch opened a third account with DBTCA. 
67. 
Deutsche Bank was aware of potential issues with FBME's compliance regime 
from very early in the active phase of the correspondent banking relationship. A May 2005, 
"Annual Anti-Money Laundering Discussion" memo for FBME, for example, shows that the 
Bank was aware that: 
a. FBME's Compliance Officer headed a department comprised of two staff 
members; 
21 
EFTA00151515

b. the Compliance Officer was at the time "trying to develop a back office 
compliance [SIC]"; 
c. FBME was at the time still using a transaction monitoring system that was 
partially manual; and 
d. FBME at the time considered the cost of compliance with AML and KYC 
regulations to be the most significant issue challenging the Cyprus banking sector. 
68. 
Later-in-time "Anti-Money Laundering Discussions" for FBME showed that 
certain aspects of FBME's compliance program did not change over subsequent years, although 
those memos did reflect that the number of AML Compliance staff at FBME generally increased 
each year between 2005 and 2013 and FBME implemented automated transaction monitoring 
and sanction screening tools in 2009 and 2010, respectively. 
69. 
On November 17, 2005, Deutsche Bank's North American Client Screening 
Committee ("CSC") assigned FBME a Risk Assessment Customer ("RAC") score of eight, 
thereby designating it as a high-risk client. At Deutsche Bank, RAC scores are graded on a scale 
of one to ten, with one being the lowest level of risk and ten the highest. Clients who receive a 
score of eight and above are considered high-risk. 
70. 
During the relevant period, FBME Cyprus was always rated high-risk, with 
Deutsche Bank's records indicating that it was assigned a RAC score, over the years, of eight or 
nine. The Bank's records show that FBME Tanzania over this time period had a RAC score of 
seven in 2007, and eight thereafter. 
71. 
At the time of the initial risk rating, information provided to the CSC included 
that other banks had alleged in the past that FBME had been associated with money laundering 
linked to Russian organized crime. A 2005 memo provided to the CSC stated that the USA 
22 
EFTA00151516

PATRIOT Act and the EU Money Laundering Directive limited FBME's ability to commit 
money laundering in the hypothetical event that it chose to engage in such conduct. The same 
memo noted that the Central Bank of Cyprus ("CBC") had represented to Deutsche Bank that the 
CBC regarded FBME as excellent from a KYC and AML perspective, and that FBME's 
Compliance Officer was the most experienced in the Cypriot market. This, in part, served as the 
justification of Deutsche Bank's continued relationship with FBME. 
72. 
In January 2007, a former Bank Director of U.S. Anti-Financial Crimes (herein, 
"AML COMPLIANCE DIRECTOR-1"), along with executives from Deutsche Bank's Greece 
office, met with FBME executives in Cyprus. Over the course of this meeting and subsequent in-
person meetings, Deutsche Bank executives became well aware of the state of FBME's 
compliance operations and provided annual seminars or "AML workshops" for Cypriot clients, 
including FBME, starting in June 2010. 
73. 
In March 2007, FBME's Cyprus branch, opened a fourth account with Deutsche 
Bank's New York Branch. 
74. 
Since 2008, the Bank identified a total of 826 suspicious transactions that 
referenced FBME, with 96 alone in 2008. That year, Deutsche Bank performed an analysis of the 
volume of suspicious transactions related to FBME and concluded that FBME presented an 
average to greater-than-average risk compared to other banks in an already high-risk market. 
75. 
This number increased to 125 suspicious transactions in 2009 and eventually 
peaked at 132 the following year. While the number of suspicious transactions decreased to 77 in 
2012, there was a significant increase in 2014, with the Bank identifying a total of 131 suspicious 
transactions concerning FBME. 
23 
EFTA00151517

76. 
Despite the high number of suspicious transactions in relation to FBME, the Bank 
facilitated 478,379 dollar-denominated transactions totaling more than $618 billion over the 
course of the relationship. 
77. 
In communications with Deutsche Bank, FBME sometimes refused to disclose in 
writing the ultimate beneficial owners of its own corporate clients, explaining that such 
information could not be shared without violating local law. For example, in March of 2007, a 
Deutsche Bank official in Greece contacted FBME concerning additional information regarding 
OFFSHORE COMPANY-1. In response, FBME stated that the company was a privately-owned 
company whose business activities included trading in securities and that FBME had conducted 
their own due diligence checks which identified the beneficial owner. However, FBME stated 
that it could not share the underlying information with the Bank without violating Cypriot law 
governing client confidentiality unless ordered by a court to do so. Three years later, Deutsche 
Bank flagged an additional transaction concerning OFFSHORE COMPANY-1, noting that they 
had inquired about the same FBME customer before. Despite this lack of transparency with 
respect to this FBME customer, Deutsche Bank continued its banking relationship with FBME. 
After Deutsche Bank decided to close the FBME relationship in July 2014, the U.S. Government 
determined that OFFSHORE COMPANY-1's ultimate beneficial owner was a Russian 
businessman who was affiliated with a Syrian research facility responsible for developing and 
producing non-conventional weapons. 
78. 
This was apparently not an isolated incident. Although the Department has not 
found that the Bank was aware at the time, many ultimate beneficial owners of clients of FBME 
have subsequently been associated in the press with "weapons proliferators, terrorists, and 
transnational organized criminals." 
24 
EFTA00151518

79. 
On July 15, 2014, the U.S. Treasury's Financial Crimes Enforcement Network 
("FinCEN") named FBME a foreign financial institution of primary money laundering concern 
pursuant to Section 311 of the USA PATRIOT Act (the "311 Designation"), and proposed 
prohibiting U.S. financial institutions from opening or maintaining correspondent accounts or 
payable through accounts for or on behalf of FBME. 
80. 
At this time, Deutsche Bank was the largest of the few remaining Western banks 
that had continued to maintain correspondent banking relationships with FBME. 
81. 
In response to the 311 Designation, Deutsche Bank decided by July 18, 2014 to 
end its relationship with FBME. 
82. 
The Department concludes that the high-risk nature of the FBME relationship, the 
red flags, numerous suspicious transactions, and overt lack of transparency exhibited by FBME 
should have prompted Deutsche Bank to exit the relationship before the 311 Designation, yet it 
failed to do so. 
Danske Estonia 
83. 
In 2007, Danske Bank A/S, the largest financial institution in Denmark, acquired 
the Baltic business of a Finnish financial institution, Sampo Bank. The segment of the business 
located in the nation of Estonia became known as Danske Estonia. 
84. 
The relationship between Deutsche Bank and Danske Estonia began on October 1, 
2007, with the latter institution's opening of a correspondent banking account with Deutsche 
Bank. Deutsche Bank assigned Danske Estonia a RAC Score of eight in 2007, i.e., high-risk, due 
to Danske Estonia's high-risk jurisdiction, the volume of AML alerts and cases involving Danske 
Estonia's customers, and the high-risk market segments serviced by Danske Estonia. 
25 
EFTA00151519

85. 
Because it was a high-risk client, Danske Estonia was required to undergo annual 
due diligence reviews as part of the Bank's KYC process for correspondent banking clients. This 
process included a discussion between the client relationship manager and Danske Estonia 
personnel focused on AML and KYC issues, including any changes in the relevant laws and 
regulations, changes to the client's internal policies and procedures, major banking issues in the 
client's country, and the client's risk analysis of its own customers. 
86. 
By June 2008, Deutsche Bank was aware of issues at Danske Estonia concerning 
its non-resident customer accounts. Specifically, Deutsche Bank observed an increase in AML-
related alerts generated by the Bank's monitoring systems involving non-resident customers of 
Danske Estonia "with a Russian or Latvian (indirectly Russia[n]) connection." These AML alerts 
prompted Bank officials from the U.S. and Germany to meet with Danske Estonia in New York, 
at which point they were assured that Danske Estonia was moving away from its non-resident 
client portfolio. 
87. 
Additionally, a plan to place the Estonian Branch on the same IT platform as 
Danske's home office fell through in 2008. Failure to implement the IT protocols resulted in the 
Estonian Branch not having the same AML checks as Danske Bank's home office, despite its 
location in a higher-risk jurisdiction. 
88. 
In July 2009, Deutsche Bank was sufficiently concerned about AML risks posed 
by Danske Estonia that AML COMPLIANCE DIRECTOR-I provided on-site training to Danske 
Estonia staff to address AML and KYC topics, which consisted of an overview of U.S. 
regulatory requirements. 
26 
EFTA00151520

89. 
Just a few months later, in November 2009, Deutsche Bank increased Danske 
Estonia's RAC score to a nine due to the lack of improvement in compliance seen at the client 
bank, despite its assurances a year earlier. 
90. 
In September 2010, Deutsche Bank elected to increase Danske Estonia's RAC 
score again, to a ten, the maximum on the Bank's risk scale, after it continued to see insufficient 
improvements from Danske Estonia regarding its non-resident customer portfolio. The score was 
expressly based on "the volume and nature" of suspicious activity involving Danske Estonia and 
its customers, as well as "law enforcement inquiries related to Danske Estonia and its 
customers." Despite this lack of improvement, the Bank elected to continue its relationship with 
Danske Estonia. 
91. 
Deutsche Bank's perception that Danske Bank was not improving was accurate. 
Danske Estonia saw a notable increase in non-residential business from Russia and other former 
Soviet states in 2010. This business was disproportionately large and lucrative for Danske Bank 
— in 2011 alone, Danske Estonia generated 11% of Danske Bank's total profits despite only 
accounting for 0.5% of the bank's assets. 
92. 
In April 2011, AML COMPLIANCE DIRECTOR-1 and other Bank employees 
met with Danske Estonia personnel once again to discuss Deutsche Bank's concerns regarding 
the volume of AML investigations involving Danske Estonia customers. During the April 2011 
meeting, Deutsche Bank personnel expressed concerns to Danske Estonia involving its non-
resident portfolio. In particular, the Bank noted that it would need to consider reassessing its 
relationship, including possible termination of Danske Estonia's accounts, unless Danske Estonia 
was able to mitigate the AML-related issues involving its non-resident customers. The number of 
27 
EFTA00151521

suspicious transactions involving Danske Estonia's customers slightly decreased between 2010 
(21 transactions) and 2011 (17 transactions). 
93. 
These concerns persisted, however, and the question of whether to retain Danske 
Estonia as a client was raised again in late 2013. In a November I, 2013 email, AML 
COMPLIANCE DIRECTOR-1 stated that Deutsche Bank was "[o]nce again, not happy with 
what [they had] experience[d] with some of Danske Bank Estonia's clients in addition to some 
AML and sanctions controls." AML COMPLIANCE DIRECTOR-1 further stated that the Bank 
"value[s] the relationship [with Danske Estonia], but must see improvements." 
94. 
The following week, on November 6, 2013, AML COMPLIANCE DIRECTOR-1 
drafted an internal memorandum after conducting an on-site visit at Danske Estonia. The draft 
memorandum concluded that there was a "basis for closure" of the Danske Estonia accounts 
largely due to a lack of improvements in AML controls. The memorandum also advocated that 
the Bank limit Danske Estonia's transactions to processing payments which originated from 
Danske Estonia's customers who were residents of Estonia. This draft memorandum does not 
appear to have been sent to any other Deutsche Bank personnel (or third party) prior to the 
termination of the Danske Estonia correspondent banking relationship in October 2015. 
95. 
Two days later, on November 8, 2013, U.S. AFC officers from the Bank had a 
phone conversation with their colleagues in Germany. On that call, concerns were raised 
regarding recent law enforcement inquiries into Danske Estonia's customers, as well as an 
increase in suspicious transactions. It was also mentioned during the call that Danske Estonia 
was "not cooperative enough" and had "not improved," despite the Bank's suggestions. This was 
subsequently discussed in an in-person meeting on November 20, 2013, in which AML 
28 
EFTA00151522

COMPLIANCE DIRECTOR-1 advocated to maintain the relationship while mitigating the risks 
involving Danske Estonia's non-resident customer portfolio. 
96. 
Notwithstanding these concerns, Deutsche Bank decided to maintain the 
relationship for two reasons: 1) Danske Estonia was viewed an important component of the 
Bank's global relationship with Danske Bank A/S; and 2) Deutsche Bank believed that it could 
effectively mitigate and control the risks. 
97. 
By early 2014, other major Western financial institutions began de-risking efforts 
in the Baltic region related to money laundering risks. Deutsche Bank elected to continue to do 
business in the region, however. 
98. 
The Bank was aware that the risks mostly centered on high-risk non-resident 
("HRNR") accounts held in the region with beneficial owners located largely in Russia and other 
former Soviet states. When later questioned about whether Deutsche Bank was concerned with 
the volume of HRNR accounts maintained at Danske Estonia and other financial institutions 
based in the Baltics, the Bank's relationship manager stated that "there were legitimate reasons 
for former Soviet businesses and individuals to use non-resident banks," and that "such 
customers often operated and lived under governments that were corrupt and rapacious, and thus 
there were valid reasons for them to hold their money overseas." 
99. 
In response to the Bank's efforts to mitigate and control the AML risk posed by 
Danske Estonia, Danske Estonia did in fact undergo some reforms over the course of 2014, but 
these underscored the failings up to that point. For example: 
a. Danske Estonia introduced a "customer risk level determination" procedure, the 
first change in five years to Danske Estonia's policies and procedures for 
evaluating a client's risk. 
29 
EFTA00151523

b. While Danske Estonia had previously screened outgoing payments against the 
U.S. Treasury Department's Office of Foreign Asset Control and European Union 
sanctions lists, it began screening incoming payments against those lists. 
100. 
Deutsche Bank was aware of the lack of such reforms prior to 2014. For example, 
Deutsche Bank's annual AML Discussions, which were required by internal Bank policy for 
high-risk clients, reflect that certain aspects of Danske Estonia's AML/KYC program were 
largely holdovers from the Sampo Bank era, with the AML Discussions simply listing "[n]o 
changes to previous discussion," year after year, with only minor changes. 
101. 
On September 29, 2014, AML COMPLIANCE DIRECTOR-1 stated in a 
transition memo that "the Baltics suffer from an inherently high client AML risk .... 
[C]ontinued monitoring should be placed on . . . Danske Bank Estonia. If the situation for 
Danske Bank Estonia worsens, I recommend that the account be closed." 
102. 
Despite this recommendation from a high-ranking and seasoned compliance 
professional, Deutsche Bank continued its relationship with Danske Estonia yet again. 
103. 
During the eight-year period between 2007 and 2015, Deutsche Bank cleared 
more than $267 billion in 1,638,844 transactions for Danske Estonia. Out of this total, Danske 
transferred at least $150 billion in payments from Russia and other former Soviet states through 
Deutsche Bank. 
104. 
Between 2007 and 2015, Deutsche Bank identified a total of 340 suspicious 
transactions that referenced Danske Estonia's U.S. dollar correspondent accounts. The high 
number of suspicious transactions, the history of high RAC scores, and various dialogues that the 
Bank had with its client concerning AML policies and controls, put Deutsche Bank on notice that 
there were issues that required timely further action. 
30 
EFTA00151524

105. 
Despite this, the Bank maintained its relationship with Danske Estonia until 
October 7, 2015, a year in which Deutsche Bank identified 87 additional suspicious transactions 
concerning Danske Estonia. 
The Bank's Compliance Failures in its Correspondent Banking Relationships 
106. 
In connection with the Bank's relationships with these high-risk correspondent 
banking customers, the Bank failed to maintain policies that set out sufficiently specific criteria, 
such as patterns of high RAC scores or high suspicious activity volumes, under which the Bank 
would determine whether to terminate a correspondent banking relationship or whether lesser 
risk-mitigation measures would be appropriate. 
107. 
During part of these relationships, the Bank failed to maintain policies that clearly 
provided for the closure of accounts based on the failure to obtain or update a USA PATRIOT 
Act certification from its correspondent banking clients. 
108. 
Finally, the Bank failed to consistently maintain policies that provided practical 
guidance to facilitate their implementation, such as procedures for determining whether other 
foreign banks use the respondent's correspondent account, or explanations of how employees 
could verify the identities of respondents' beneficial owners. 
D. 
Deutsche Bank's Substantial Cooperation and Remediation 
109. 
The Department recognizes and credits the Bank's exemplary cooperation during 
the course of the Department's investigations of the Bank's former relationships with Danske 
Bank, FBME, and Jeffrey Epstein. This cooperation, which occurred over several years, included 
conducting comprehensive and thorough internal investigations of each of those former 
relationships and sharing the results of those investigations with the Department in a detailed and 
transparent manner; collecting, analyzing and producing numerous documents and other 
31 
EFTA00151525

information to the Department; and providing timely and detailed responses to the Department's 
inquiries. 
110. 
The Department also recognizes and credits the Bank's ongoing efforts to 
remediate the shortcomings identified in this Consent Order, including the fact that these efforts 
commenced before the inception of the Department's investigations of the former relationships 
described herein. Among other things, the Bank has demonstrated its commitment to remediation 
by devoting significant financial and other resources to enhance the Bank's AML program, 
including through changes to its policies, procedures, systems, governance structures, and 
personnel, as well as its ongoing cooperation with the independent monitor selected by the 
Department (as referenced in paragraph 117 below), and by reducing the Bank's portfolio of 
high-risk clients in its correspondent banking and Wealth Management businesses. 
III. 
Consistent with the requirements of New York Banking Law § 44(5), the 
Department has given substantial weight to the commendable conduct described in paragraphs 
109 and 110 above. 
Violations of Laws and Regulations 
112. 
The Department finds that Deutsche Bank conducted business in an unsafe and 
unsound manner, in violation of New York Banking Law § 44. 
113. 
The Department finds that Deutsche Bank failed to maintain an effective and 
compliant anti-money laundering program, in violation of 3 NYCRR § 116.2. 
NOW THEREFORE, to resolve this matter without further proceedings, pursuant to the 
Superintendent's authority under Sections 39 and 44 of the Banking Law, the Department and 
Respondents stipulate and agree to the following terms and conditions: 
32 
EFTA00151526

SETTLEMENT PROVISIONS 
Monetary Penalty 
114. 
Deutsche Bank shall pay a penalty to the Department, pursuant to New York 
Banking Law §§ 39 and 44, in the amount of one hundred fifty million U.S. dollars 
($150,000,000.00). The entire amount shall be paid to the Department within ten (10) business 
days of executing this Consent Order. 
115. 
Deutsche Bank agrees that it will not claim, assert, or apply for a tax deduction or 
tax credit with regard to any U.S. federal, state, or local tax, directly or indirectly, for any portion 
of the civil monetary penalty paid pursuant to this Consent Order. 
116. 
Deutsche Bank further agrees that it shall neither seek nor accept, directly or 
indirectly, reimbursement or indemnification with respect to payment of the penalty amount, 
including but not limited to payment made pursuant to any insurance policy. 
Remediation 
117. 
An independent monitor selected by the Department is already engaged to assist 
the Bank pursuant to the Consent Order entered into between the Bank and the Department dated 
January 30, 2017. The Department has directed the monitor to address the compliance failures 
implicated by the instant Consent Order in the context and within the timetables of that 
engagement. The Bank reconfirms its commitment to cooperate fully with the monitor and 
acknowledges that, although no extension of the monitorship is currently contemplated, the 
Department may, in its sole regulatory discretion, extend the scope of duration of the 
monitorship to address the Bank's failures described herein. 
33 
EFTA00151527

Full and Complete Cooperation 
118. 
The Bank commits and agrees that it will fully cooperate with the Department 
regarding all terms of this Consent Order, and as noted above, the Bank has already provided 
exemplary cooperation in these and related matters. 
Waiver of Rights 
119. 
The parties understand and agree that no provision of this Consent Order is 
subject to review in any court or tribunal outside the Department. 
Parties Bound by the Consent Order 
120. 
This Consent Order is binding on the Department, Deutsche Bank, including its 
New York Branch, as well as any of their successors and assigns. This Consent Order does not 
bind any federal or other state agency or any law enforcement authority. 
121. 
No further action will be taken by the Department against the Bank for the 
conduct set forth in this Consent Order provided that the Bank complies with the terms of this 
Consent Order. For the sake of clarity, such conduct includes (a) the Bank's AML control 
deficiencies with respect to the onboarding and monitoring of foreign bank customers to whom 
the Bank provided dollar-clearing services through the date of this Order, including but not 
limited to the Bank's relationships with FBME and Danske Estonia discussed herein, but only to 
the extent that such deficiencies do not constitute knowing and willful misconduct that would be 
subject to penalty under New York Banking Law § 44(4); and (b) the Bank's relationship with 
Jeffrey Epstein and related individuals and entities. 
122. 
Notwithstanding any other provision in this Consent Order, the Department may 
undertake action against Deutsche Bank for transactions or conduct in connection with FBME, 
Danske Bank, and Jeffrey Epstein and his related entities that Deutsche Bank did not disclose to 
34 
EFTA00151528

the Department in the presentations and written materials submitted to the Department in 
connection with these matters. 
Breach of Consent Order 
123. 
In the event that the Department believes any party to this Consent Order to be in 
material breach of the Consent Order, the Department will provide written notice to the party, 
and the party must, within ten (10) business days of receiving such notice, or on a later date if so 
determined in the Department's sole discretion, appear before the Department to demonstrate 
that no material breach has occurred or, to the extent pertinent, that the breach is not material or 
has been cured. 
124. 
The parties understand and agree that any party's failure to make the required 
showing within the designated time period shall be presumptive evidence of that party's breach. 
Upon a finding that a breach of this Consent Order has occurred, the Department has all the 
remedies available to it under New York Banking and Financial Services Law and may use any 
evidence available to the Department in any ensuing hearings, notices, or orders. 
Notices 
125. 
All notices or communications regarding this Consent Order shall be sent to: 
For the Department: 
Terri-Anne Caplan 
Senior Assistant Deputy Superintendent for Enforcement 
New York State Department of Financial Services 
One State Street 
New York, NY 10004 
35 
EFTA00151529

Randolph Hall 
Assistant Counsel for Enforcement 
New York State Department of Financial Services 
One State Street 
New York, NY 10004 
Zachary Shapiro 
Attorney for Enforcement 
New York State Department of Financial Services 
One State Street 
New York, NY 10004 
For Deutsche Bank: 
Joe Salama 
Global Head of Litigation and Regulatory Enforcement 
60 Wall Street 
New York, NY, 10005-2836 
Andrew Stemmer 
Head of Litigation & Regulatory Enforcement - Americas 
60 Wall Street 
New York, NY, 10005-2836 
Miscellaneous 
126. 
Each provision of this Consent Order shall remain effective and enforceable until 
stayed, modified, suspended, or terminated by the Department. 
127. 
No promise, assurance, representation, or understanding other than those 
contained in this Consent Order has been made to induce any party to agree to the provisions of 
the Consent Order. 
(The remainder of this page is intentionally blank) 
36 
EFTA00151530

IN WITNESS WHEREOF, the parties have caused this Consent Order to be signed this filli day 
of July, 2020. 
NEW YORK STATE DEPARTMENT 
DEUTSCHE BANK AG 
OF FINANCIAL SERVICES 
By: 
R. BRUCE WELL 
Associate Counsel 
Consumer Protection & Financial 
Enforcement Division 
By 
• 
By: 
KEVIN R. PUVALOWSKI 
Senior Deputy Superintendent 
Consumer Protection & Financial 
Enforcement Division 
ICA 
ERINE AEMIRE
Executive Deputy Superintendent 
Consumer Protection & Financial 
Enforcement Division 
By: 
Karen Kuder 
General Counsel 
By: 
Thorsten Seyfried 
General Counsel — Germany and 
EMEA 
DEUTSCHE BANK AG, 
NEW YORK BRANCH 
By: 
Joe Salama 
Global Head of Litigation and 
Regulatory Enforcement 
By: 
By: 
kist 
Ac-4^-141A 
Andrew Stemmer 
Head of Litigation & Regulatory 
LINDA A. LACEWELL 
Enforcement - Americas 
Superintendent of Financial Services 
DEUTSCHE BANK TRUST 
COMPANY OF THE AMERICAS 
By: 
Joe Salama 
Global Head of Litigation and 
Regulatory Enforcement 
By: 
Andrew Stemmer 
Head of Litigation & Regulatory 
Enforcement - Americas 
37 
EFTA00151531

IN WITNESS WHEREOF, the parties have caused this Consent Order to be signed this 6th day 
of July, 2020. 
NEW YORK STATE DEPARTMENT 
OF FINANCIAL SERVICES 
By: 
R. BRUCE WELLS 
Associate Counsel 
Consumer Protection & Financial 
Enforcement Division 
By: 
KEVIN R. PUVALOWSKI 
Senior Deputy Superintendent 
Consumer Protection & Financial 
Enforcement Division 
By: 
KATHERINE A. LEMIRE 
Executive Deputy Superintendent 
Consumer Protection & Financial 
Enforcement Division 
By: 
LINDA A. LACEWELL 
Superintendent of Financial Services 
37 
DEUTSCHE BANK AG 
By: 
/C14,10,  /C41.411. 
By: 
Karen Kuder 
General C 
Thorsten Seyfrt 
General Counsel 
EMEA 
Germany and 
DEUTSCHE BANK AG, 
NEW YORK BRANCH 
By: 
e. &lama-
Salama 
Global Head of Litigation and 
Regulatory Enforcement 
By: Attiviafr• St unkta 
Andrew Stemmer 
Head of Litigation & Regulatory 
Enforcement — Americas 
DEUTSCHE BANK TRUST 
COMPANY OF THE AMERICAS 
By: 
Sakfrita• 
Salama 
Global H 
By: 
f Litigation and 
ement 
Steven F. Reich 
General Counsel — Americas 
EFTA00151532