Prosecutors say the inquiry concerns suspected AML breaches linked to past transactions.
Deutsche Bank has confirmed that prosecutors from Frankfurt were present at its offices this week as part of an investigation linked to historic transactions and the filing of a suspicious activity report.
In a statement issued via a spokesperson to Payment Expert, the bank said that the visit by the Staatsanwaltschaft Frankfurt am Main relates to transactions dating back to the period between 2013 and 2018, and centres on what it described as an allegedly late filing of a suspicious activity report (SAR).
“This is related to transactions dating back to the period 2013–2018. It is based on an allegedly late filing of a suspicious activity report. On this basis, the prosecutor is assessing whether there was any potential money laundering,” the bank said. It added that it is “fully cooperating with the public prosecutor’s office”.
The Frankfurt public prosecutor’s office has since confirmed that its economic crimes unit, working alongside the Federal Criminal Police Office (BKA) in Wiesbaden, is conducting an investigation against “unknown responsible persons and employees of Deutsche Bank”.
According to a statement from the prosecutor’s office sent to Payment Expert, the investigation concerns suspected money laundering under section 261 of the German Criminal Code, alongside related allegations under Germany’s Money Laundering Act. Prosecutors say Deutsche Bank had, in the past, maintained business relationships with foreign companies that are themselves suspected of having been used for money laundering purposes in the context of further investigations.
“To further clarify the facts, a search warrant issued by the Frankfurt am Main District Court is being executed at the locations of Deutsche Bank AG in Frankfurt am Main and Berlin,” the prosecutor’s office says. It added that no further information could be provided at this stage regarding the background of the business relationships, the transactions conducted through the bank, their scope, or the companies involved.
The prosecutor’s statement does not allege that Deutsche Bank itself engaged in money laundering, nor does it identify any named suspects. As is customary in Germany, investigations at this stage are conducted against unnamed individuals while evidence is gathered.
Deutsche Bank has emphasised that the matter relates to historic transactions and reporting processes, rather than current operations. The period referenced predates a number of compliance reforms introduced by the lender following earlier regulatory scrutiny, including changes to transaction monitoring, internal escalation procedures and AML reporting frameworks.
The investigation remains ongoing, and no charges have been brought.
European AML reporting obligations
Under European anti-money laundering rules, banks and other regulated entities are required to file SARs without delay where there are reasonable grounds to suspect money laundering or terrorist financing.
At EU level, these obligations are set out under successive Anti-Money Laundering Directives (AMLDs), which have been transposed into national law by member states. In Germany, the requirement to report suspicious activity applies regardless of whether a transaction is ultimately completed, and extends to cases where suspicions arise retrospectively.
While EU legislation does not prescribe a fixed number of days for filing a SAR, regulators and prosecutors typically interpret the obligation as requiring prompt reporting once suspicion is formed, rather than after an internal investigation has concluded. Delays can therefore become a point of scrutiny where authorities believe a report should have been filed earlier, even if no underlying criminal activity is ultimately established.
SARs in Germany are submitted to the Financial Intelligence Unit (FIU), which is responsible for analysing reports and, where appropriate, referring cases to law enforcement. Prosecutors may assess whether reporting obligations were met in a timely manner as part of wider investigations into potential money laundering controls and compliance processes.
