What happens when you have inadequate controls to prevent non-compliance with the law? You get publicly scolded by the regulator?
“Regulator Scolds Deutsche Bank on Money-Laundering Controls,” September 25, 2018 B11. German authorities also require the appointment of an independent monitor (KPMG). This monitor will join the other monitors appointed by various US authorities.
Is this enough? Certainly disruptive and expensive for the bank, but will it have lasting impact? Is the German government serious about compliance with these laws? Until a director or senior officer gets punished, will the controls really be effective?