Deutsche Bank AG: Bafin sets new deadlines for remedying shortcomings

On 15 September 2026, Bafin set new deadlines for Deutsche Bank AG to remedy shortcomings in its data processing systems. These systems are used to monitor transactions for the purpose of preventing money laundering and terrorist financing.

This order is issued on the basis of section 51 (2) sentence 1 of the German Money Laundering Act (GwG) in conjunction with section 25h (5) of the German Banking Act (KWG).

The notice became final and binding on 6 October 2026.

Under section 25h (1) to (3) of the KWG as well as section 6 (2) no. 1 (e) and section 10 (1) no. 5 of the GwG, credit institutions are required to operate data processing systems in order to identify suspicious business relationships and transactions in the payments area (i.e. “transaction monitoring”). Systematic transaction monitoring by credit institutions is necessary for the detection of suspicious activities and subsequent reporting of relevant transactions to the Financial Intelligence Unit (FIU). These systems must be continuously updated to ensure their reliability.

Bafin had already ordered Deutsche Bank AG in April 2021 and November 2023 to promptly remedy shortcomings in the bank’s transaction monitoring with the aim of improving its data processing systems. The orders issued in 2021 and 2023 were intended to compel the bank to ensure, within a specified timeframe, that its data processing systems are functional in accordance with statutory and supervisory requirements.

The order of 15 September 2026 updates these earlier orders, as a reorganisation of the bank’s transaction monitoring system due to changes in technical requirements necessitated new deadlines for remedying the shortcomings in some cases.