Anti-money laundering, anti-corruption and international sanctions

DNB Bjrvika
In DNB we work resolutely to prevent and detect money laundering, terrorist financing, corruption, and breaches of international sanctions.
Financial crime is a serious threat to our society and undermines healthy and sustainable business operations. Among other things, financial crime includes money laundering, terrorist financing, corruption, and breaches of international sanctions. At DNB, we prioritise efforts to prevent and detect financial crime. An overarching goal of our work is to reduce financial losses for society, our customers and DNB, and to maintain people’s trust in our products and services. This work is an important part of our societal responsibility.

Three lines of defence

The work of preventing financial crime and ensuring compliance with relevant rules and legislation takes place within three lines of defence: 

The first line of defence includes all DNB Group’s operative functions and consists of business areas, staff and support units. Our employees are responsible for ensuring good internal control in their daily work. The first line of defence has direct contact with our customers and knows them best.

The second line of defence consists of our Risk Management and Compliance functions. Risk Management and Compliance and are two independent control functions that monitor, control, and follow up managers and employees in the DNB Group’s operative functions.

The third line of defence is Group Audit. Group Audit assists the Board in ensuring that all significant elements of the DNB Group’s internal control, including risk management and compliance, are of satisfactory quality.
Trapp i Bjrvika

Preventive work

To ensure effective efforts in preventing money laundering, terrorist financing, corruption and breaches of international sanctions, we have to:

Know our customers, business partners and suppliers.
- Monitor transactions to and from accounts in DNB.
- Assess, understand and manage risks the DNB Group is exposed to.
- Take a comprehensive approach to our work, across different specialist areas and business areas.

In addition, our preventive work consists of the following six main elements:
- Top level commitment
- Risk assessments
- Procedures and processes
- Customer due diligence, including background checks and ongoing due diligence
- Training
- Monitoring

Risk assessments

As mentioned above, DNB must understand the risks related to our business operations. We must understand how the DNB Group could be misused for financial crime, and we continuously work to identify relevant risk factors. Both international and national authorities expect the bank to maintain an overview of these risk factors.

DNB prepares annual risk assessments related to money laundering and terrorist financing, corruption, and breaches of international sanctions. These risk assessments provide an overview of all relevant risk factors. Furthermore, they form the basis for the measures and controls we need to implement within the DNB Group, and vis-à-vis our customers, suppliers, and business partners, to manage the risk we are exposed to.

The DNB Group’s overall risk assessments consist of three parts:

1. DNB’s Group-wide assessment of inherent risk of
- Money laundering and terrorist financing
- Corruption
- Breaches of international sanctions

2. Specific risk assessments of DNB entities and their ‘residual risk’ in each area

3. Aggregated Group-wide assessments of residual risk in each area

Inherent risk means the risk that exists before taking into account preventive measures. Through assessments of inherent risk, we identify which of DNB’s business areas, products and services, customers and third parties are considered to involve a risk of being misused for financial crime. Once we have identified risk factors and implemented risk-based preventive measures, we are left with ‘residual risk’.

Anti-money laundering and counter-terrorist financing

Money laundering means securing the proceeds of criminal activity and integrating this money into the legal economy. The purpose is to make it look as if the proceeds have been earned legally, and to hide the fact that they have been generated by criminal activity.

Terrorist financing means the provision or collection of funds, by any means, directly or indirectly, with the intention that they be used to carry out terrorist acts. The duty to uncover and prevent terrorist financing is not focused on the origin of the money, but on what the money is to be used for.

As banking activities entail a risk of being exploited for money laundering, the Norwegian Anti-Money Laundering Act requires banks to implement a range of measures. The authorities have the primary responsibility for combating criminal activity, but banks and other financial institutions are obliged to contribute in various ways to uncover and prevent money laundering and terrorist financing.

DNB needs to know its customers
Knowing our customers enables us to detect whether a customer’s use of the bank may be related to money laundering or terrorist financing. To that end, we obtain information about who our customers are and how they plan to use the bank. We obtain this information when establishing customer relationships, and we review and update it on an ongoing basis.

We ask a number of questions and require documentation to get to know our customers better. This job must be done thoroughly, which means that in some cases opening an account may take time. We regularly ask customers questions, but this doesn’t mean that something illegal has taken place. This is as much a matter of ensuring good and secure services for our customers, as it is a matter of stopping those with dishonest intentions.

DNB must monitor customer transactions
Every single day more than nine million transactions are made to and from accounts in DNB. These transactions are screened through our electronic monitoring system. If we cannot understand the background or the purpose of a transaction, we will examine the circumstances surrounding the transaction and report it to Økokrim (the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime) if necessary. The threshold for reporting to Økokrim is low. It is Økokrim that investigates whether a criminal act has taken place. The bank has a duty of confidentiality in relation to examinations of suspicious transactions and is not permitted to inform customers or others of our assessments.

DNB’s assessment of the risk of money laundering and terrorist financing
As mentioned above, the DNB Group must understand the risks we are exposed to. Here is the official risk assessment of our exposure to risks related to money laundering and terrorist financing.


Corruption is offering or giving and accepting or receiving an undue advantage in connection with the undertaking of a position, office or assignment. Both individuals working in DNB and the DNB Group as a whole can be held criminally liable for corruption.

Corruption is punishable under both Norwegian and international rules and legislation. DNB operates in multiple locations worldwide and is obliged to adhere to the corruption rules and legislation applicable to our business operations at any given time. DNB has dealings with a variety of players including customers, suppliers, agents and other business partners and public authorities. As a player in Norwegian society, DNB has a responsibility to prevent corruption.

The DNB Group has zero tolerance for corruption. The purpose of our anti-corruption efforts is to:
- Prevent persons acting on behalf of the DNB Group from committing active or passive corruption or contributing to corruption.
- Prevent DNB Group products and services from being misused for corruption.
- Identify whether active or passive corruption, or complicity in it, occurs nevertheless.
- Give guidance on how corruption incidents should be handled.

Our employees meet our customers, business partners and suppliers on a daily basis. A key aspect of DNB’s anti-corruption efforts is to empower our employees to respond if they encounter attempts at corruption. We ensure transparency and traceability to prevent any doubt about the integrity of the DNB Group and our employees. Training and competence-building related to corruption risk is crucial for achieving this goal.

We also maintain a zero-tolerance policy for the use of DNB’s products and services to facilitate corruption, such as a bribery transaction through DNB. By its nature, a bribery transaction involves money laundering of the proceeds of corruption. This aspect of corruption risk is consequently addressed through the bank’s anti-money laundering programme.

National and international authorities impose requirements for clear and robust measures to prevent corruption. DNB must understand, identify and assess the risk of corruption associated with our business operations. This entails knowing both our customers, suppliers, and business partners. Furthermore, it is essential that we continuously work to identify and evaluate the risk of the bank being misused for corruption, either directly or by means of bribery transactions passing through our systems.

DNB’s assessment of corruption risk
As mentioned above, the DNB Group must understand the risks we are exposed to. Here is the official risk assessment of our exposure to risks related to corruption.

International sanctions

Sanctions is a general term used to refer to non-military actions adopted by national governments or international organisations (primarily the UN Security Council and the EU) to further their foreign and security policy objectives. Sanctions are economic or diplomatic restrictions imposed on a state, a regime, companies, or individuals. The purpose of sanctions is to encourage change in the policies or conduct of those targeted, for example by limiting the party’s economic and material ability to commit undesirable acts.

DNB is exposed to international sanctions regimes in several respects. Firstly, DNB’s business operations involve a number of parties in many different countries, including employees, customers, suppliers, correspondent banks and other business partners, as well as public authorities. Secondly, the DNB Group provides and purchases products and services that may directly or indirectly involve exposure to international sanctions. Thirdly, our customers’ business partners may represent a sanctions risk for DNB if DNB is involved in transactions with these third parties.

Among other things, DNB is required to freeze transactions that are in violation of international sanctions. Furthermore, we must not be misused to circumvent rules and legislation. We therefore screen our customers and their transactions against sanctions lists. However, screening alone is not enough, which is why we must know our customers. We must also ensure that we have up-to-date knowledge of relevant rules and legislation. These are subject to frequent changes, and different parts of the DNB Group’s areas of operation are subject to different sanctions regimes.

The authorities, both national and international, have high expectations of financial institutions to develop, implement and routinely update a sanctions compliance programme. The programme must be adapted to the company’s risk exposure.

Performing risk assessments is a basic prerequisite for identifying, assessing and managing DNB’s sanctions risk. Risk assessments are therefore the foundation of DNB’s sanctions compliance programme.

DNBs assesment of sancions risk

As mentioned above, the DNB Group must understand the risks we are exposed to. Here is the official risk assessment of our exposure to risks related to breaches of international sanctions.