Clifford Chance delivers its Report on an extensive anti-money laundering and OFAC sanctions investigation into major Swedish bank Swedbank AB (publ) ("Swedbank") to the Swedbank Board of Directors.
The investigation commenced in February 2019 and examined conduct during the period from 2007 to March 2019, focusing on customers and transaction activity by Swedbank's three Baltic Subsidiaries for AML risk and OFAC sanctions exposure, and the manner in which Swedbank managed that risk. The Firm also examined how Swedbank responded historically to identified AML and sanctions control deficiencies and handled internal escalation and public disclosures.
Swedbank publicly has released the report today, which can be found at www.swedbank.com
David D. DiBari, Clifford Chance's Co-Head of Global Risk, US Head of Litigation & Dispute Resolution, and Managing Partner of the Washington DC office, led the matter, which also included partners and subject matter specialists Daniel Silver, Michelle Williams, Celeste Koeleveld, Glen Donath, Steve Gatti, Robert Houck, Steve Nickelsburg, George Kleinfeld, Megan Gordon and Michael Lyons, Clifford Chance internal forensic accountants led by Telmo Pereira, and lawyers and professionals from 13 Clifford Chance offices. FTI Consulting, an independent global business advisory firm whose specialist practices include forensic investigations, data analytics and financial crime capabilities, supported the Firm on the investigation and was led by Nick Hourigan.
DiBari said, "We are grateful to have been entrusted by the Swedbank Board with such a significant undertaking, and one Clifford Chance was uniquely positioned to perform. The Board's decision to publish our Report was a significant exercise in transparency with the market."