Commerzbank AG

🔴 High Risk

Commerzbank, one of Germany’s leading banks, has faced significant scrutiny and regulatory penalties over its anti-money laundering (AML) weaknesses and sanctions violations, marking a critical case in the global fight against financial crime. Despite its prominence and longstanding presence in international banking, the institution has been repeatedly fined for failing to maintain adequate controls to prevent illicit financial flows, including a historic $1.45 billion US fine for evading sanctions and a substantial £37.8 million fine by the UK Financial Conduct Authority for AML failings. These enforcement actions underscore systemic weaknesses in compliance and due diligence within Commerzbank, revealing how lapses at major financial institutions can pose serious risks to the integrity of the global financial system. This case highlights the ongoing challenges banks face in adhering to evolving regulatory standards and the severe consequences of non-compliance.

Commerzbank AG, a major German bank with global operations, has a historical and regulatory record involving significant breaches of economic sanctions, particularly against Iran, via the practice of wire-stripping to conceal client identities in US dollar transactions. It has also faced shortcomings in AML controls, resulting in hefty fines by US and UK regulators. The bank has been implicated in facilitating complex financial arrangements for clients involved in fraud and has been subject to investigations linked to Russian money laundering. Despite these issues, it remains a key financial institution with substantial government ownership and ongoing efforts to remediate compliance failures. The case of Commerzbank highlights the challenges global banks face in balancing cross-border financial operations with compliance to international sanctions and AML regulations, underscoring significant jurisdictional and reputational risks in the financial services sector.

Country of Incorporation

Germany

Operates widely in Germany with around 400 branches and maintains international presence in major financial centers including New York City, Singapore, Brussels, and Poland (through its subsidiary mBank).

Banking and Financial Services

  • Commercial bank with a full banking license.

  • Part of a group that includes Comdirect Bank (German online banking) and mBank (Polish subsidiary).

  • Listed publicly on the German stock exchange (DAX).

  • Historical involvement in wire-stripping in US dollar transactions to circumvent sanctions (specifically involving Iran and Sudan from 2002 to 2008).

  • Use of special purpose vehicles (SPVs) linked to helping clients (e.g., Japanese firm Olympus) with accounting fraud.

  • Deficiencies in anti-money laundering (AML) policies and transaction monitoring, as noted in regulatory actions.

  • Major shareholders as of mid-2025 include UniCredit (around 20%), the German government through the Special Fund for Financial Market Stabilization (SoFFin) (around 12%), and BlackRock (~5%).

  • Significant government ownership due to financial injections during 2008 financial crisis.

  • Board of Managing Directors includes Chairwoman and CEO Bettina Orlopp, Michael Kotzbauer, Sabine Mlnarsky, Jörg Oliveri del Castillo-Schulz, Thomas Schaufler, and Bernhard Spalt.

  • Supervisory Board chairman is Jens Weidmann.

  • Yes.

  • There were noted inadequacies in identification and screening of Politically Exposed Persons (PEPs) as per FCA investigations, with incidents of poor due diligence and risk consideration.

  • No direct links to Panama Papers or Paradise Papers were prominently noted, but Commerzbank does appear in the ICIJ Offshore Leaks database indicating some offshore entities connected to the bank.

  • Was at the center of a money laundering investigation involving Russian telecom asset transfers tied to allies of Putin, prompting searches of headquarters and executive resignation.

High – based on past sanctions violations, AML failings, and investigations related to sanctions evasion and money laundering.

  • In 2015-2020, fined $1.45 billion by US authorities (New York Department of Financial Services) for violating US sanctions on Iran and Sudan through wire-stripping and failing internal controls.

  • FCA (UK Financial Conduct Authority) fined Commerzbank London branch £37,805,400 in 2020 for AML breaches spanning 2012-2017, including failure in due diligence and transaction monitoring systems.

  • Fined €1.45 million in 2024 by BaFin (German regulator) related to AML violations at its subsidiary Comdirect Bank.

  • Legal cases including contempt proceedings related to employment tribunal scenarios.

  • Ongoing scrutiny for involvement with high-risk clients and AML compliance weaknesses.

Active. Continues to operate as one of Germany’s major banks with ongoing AML remediation efforts.

  • 1870: Founded.

  • 1971: First German bank branch in New York City.

  • 2008: Financial crisis—German government becomes major shareholder.

  • 2009: Acquired Dresdner Bank.

  • 2002-2008: Period during which sanctions violations occurred leading to US fine.

  • 2012-2017: AML failures at London branch identified, resulting in FCA fine in 2020.

  • 2019-2020: Executive resignations and leadership changes amid underperformance and enforcement actions.

  • 2024: German BaFin fines Comdirect subsidiary €1.45M for AML breaches.

  • 2024-2025: Investigations into money laundering allegations related to Russian telecom assets; senior executive resignations.

Wire-stripping, Sanctions Evasion, AML Failures, SPV Fraud

Europe (Germany, EU), North America (US), Poland, Asia (Singapore branch)

High

Commerzbank Aktiengesellschaft (Commerzbank AG)

Commerzbank
Country of Registration:
Germany
Headquarters:
Kaiserplatz, Frankfurt am Main, Germany
Jurisdiction Risk:
High
Industry/Sector:
Banking, Financial Services
Laundering Method Used:

Wire-stripping (sanctions evasion), AML Failures, Sanctions violations, SPV layering

Linked Individuals:

Bettina Orlopp (CEO), Jens Weidmann (Supervisory Board Chairman), Michael Kotzbauer, others

Known Shell Companies:

Some linked offshore entities found in ICIJ Offshore Leaks database

Offshore Links:
1
Estimated Amount Laundered:
$1.45 billion (US sanctions violation fine)
🔴 High Risk