Press Release
SEC Charges Danske Bank with Fraud for Misleading Investors about Its Anti-Money Laundering Compliance Failures in Estonia
Bank Agrees to Pay More than $400 Million to Settle SEC Charges

Washington D.C., Dec. 13, 2022 —
The Securities and Exchange Commission today announced fraud charges against Danske Bank, a multinational financial services corporation headquartered in Denmark, for misleading investors about its anti-money laundering (AML) compliance program in its Estonian branch and failing to disclose the risks posed by the program’s significant deficiencies. Danske Bank agreed to pay $413 million to settle the SEC’s charges.

According to the SEC’s complaint, when Danske Bank acquired its Estonian branch in 2007, it knew or should have known that a substantial portion of the branch’s customers were engaging in transactions that had a high risk of involving money laundering; that its internal risk management procedures were inadequate to prevent such activity; and that its AML and Know-Your-Customer procedures were not being followed and did not comply with applicable laws and rules. The SEC alleges that, from 2009 to 2016, these high-risk customers, none of whom were residents of Estonia, utilized Danske Bank’s services to transact billions of dollars in suspicious transactions through the U.S. and other countries, generating as much as 99 percent of the Estonian branch’s profits. The complaint further alleges that, although Danske Bank knew of these high-risk transactions, it made materially misleading statements and omissions in its publicly available reports stating that it complied with its AML obligations and that it had effectively managed its AML risks. As the full extent of Danske Bank’s AML failures became apparent, its share price dropped precipitously.

“Corporations that raise money from the public must disclose information that is material to investors, who then get to decide what risks they want to take. That’s the basic bargain of our securities laws and it extends to foreign issuers like Danske Bank, which sought to access our capital markets, even though its securities were not registered with the Commission,” said Gurbir S. Grewal, Director of the SEC’s Division of Enforcement. “But as alleged in our complaint, Danske Bank repeatedly broke that bargain by misrepresenting to its shareholders, including U.S. investors, that it had strong anti-money laundering controls while hiding its significant control deficiencies and compliance failures.”

The SEC’s complaint charges Danske Bank with violating the antifraud provisions of the Securities Exchange Act of 1934. Danske Bank has offered to settle the SEC’s charges by consenting to the entry of a final judgment in U.S. District Court permanently enjoining it from future violations and ordering it to pay $178.6 million in disgorgement, $55.8 million in prejudgment interest, and $178.6 million in a civil penalty. The SEC will deem the disgorgement and prejudgment interest satisfied by forfeiture and confiscation ordered in parallel criminal cases.

Danske Bank has agreed to pay more than $2 billion as part of an integrated, global resolution with the SEC, the Department of Justice, the United States Attorney’s Office for the Southern District of New York, and Denmark’s Special Crime Unit.

The SEC’s investigation was conducted by Jennifer Moore and was supervised by Tanya Beard and Tracy Combs of the Salt Lake Regional Office.



SEC. v Danske Bank A/S
Civil Action No. 7:22-CV-10509 (S.D.N.Y.)
On December 13, 2022, the Commission filed a complaint (the “Complaint”) alleging that from at least 2009 to 2016, Danske Bank A/S (“Danske”), through its Estonian branch (“Danske Estonia”), provided banking services to suspicious customers despite knowing there was a high degree of risk that such customers were potentially engaged in money laundering. The Complaint further alleged that Danske also knew or was reckless in not knowing of numerous red flags indicating that its employees and managers at Danske Estonia had, among other things, conspired with customers to circumvent the anti-money laundering (“AML”) laws and that Danske’s internal AML and “know your customer” safeguards were weak and ineffective. The Complaint also alleged that Danske knowingly or recklessly made materially misleading statements and omissions in its publicly-available reports stating that Danske was compliant with its legal obligations to prevent its services from being used for illicit purposes and that it had effectively managed these risks. See the Commission’s Complaint.
Danske Bank A/S (

Danske was ordered to pay $178.6 million in disgorgement, $55.8 million in prejudgment interest, and a civil penalty of $178.6 million. The Commission deemed the disgorgement and prejudgment interest satisfied by the forfeiture and confiscation ordered in parallel criminal cases. The Commission was ordered to hold all funds, together with interest and income earned thereon (the “Fund”), pending further order of the Court. See Final Judgment.
Danske Bank A/S (

The Commission holds $178,600,000 in the Fund in a Commission-designated account at the U.S. Department of the Treasury. Any accrued interest will be added to the Fund for the benefit of harmed investors.

On February 14, 2023, the Court granted the Commission’s motion and entered an Order that established a Fair Fund, pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, for the $178,600,000 paid by the Danske (the “Fair Fund”), so it can be distributed to investors harmed by the conduct alleged in the Complaint. The Court’s Order also appointed Miller Kaplan Arase LLP as the Tax Administrator of the Fair Fund to fulfill the tax obligations of the Fair Fund, and authorized the Commission to approve and arrange payment of all tax obligations owed by the Fair Fund and the related fees and expenses of the Tax Administrator directly from the Fair Fund without further approval of the Court. See the Court’s Order.
Danske Bank A/S (

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