The Securities and Exchange Commission has charged registered investment adviser DWS Investment Management Americas Inc., a subsidiary of Deutsche Bank AG, in two separate enforcement actions, one addressing its failure to develop a mutual fund Anti-Money Laundering program, and the other concerning misstatements regarding its Environmental, Social, and Governance investment process. To settle the charges, DIMA agreed to pay a total of $25M in penalties. In the AML action, the SEC’s order finds that DIMA caused mutual funds it advised to fail to develop and implement a reasonably designed AML program to comply with the Bank Secrecy Act and applicable Financial Crimes Enforcement Network regulations. The order also finds that DIMA caused such mutual funds’ failure to adopt and implement policies and procedures reasonably designed to detect activities indicative of money laundering and to conduct AML training specific to the mutual funds’ business.
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