Deutsche Bank

Non-Financial Report 2017

Respecting Sanctions and Embargoes

National authorities and supranational organizations (such as UN and EU) impose restrictive measures against countries, organizations, groups, entities, and individuals that infringe internationally accepted behaviors and norms, especially where these relate to weapons proliferation, terrorism, or the support of terrorist organizations, human rights violations, or corruption and bribery. Such measures are more commonly known as embargoes or sanctions.

Deutsche Bank has a responsibility to monitor, evaluate, and, if required, observe laws and binding requirements related to financial and trade sanctions set by the EU, Bundesbank, Germany’s Federal Office for Economic Affairs and Export Control, and other authorities, such as the US Office of Foreign Assets Control (OFAC) and the UK Treasury Department.

Our Group-wide Embargo Policy, Special Risk Country Policy, and a specific Office of Foreign Assets Control Policy help us to assess and reduce client risk as part of our on-boarding processes and periodically thereafter. It also helps us to manage risks related to particular transactions, countries, and goods.

In the wake of the implementation of the Joint Comprehensive Plan of Action entered into by world powers and Iran at the start of 2016, we have very cautiously relaxed our otherwise stringent policy towards Iran and, in 2017, we continued to execute legal payments in euros on behalf of our long-standing clients, subject to enhanced due diligence.

Please note that the bank has entered into agreements with certain U.S. regulatory and law enforcement agencies to resolve investigations concerning U.S. Embargoes-Related Matters as further outlined in our Annual Report 2017, Notes to the Consolidated Balance Sheet, Note 29 – Provisions – Current Individual Proceedings – U.S. Embargoes-Related Matters.