Despite its major firms being caught up in the Danske Bank scandal, there did not appear to be any particular new focus on culture or conduct risk by German regulators during 2018.
The Federal Financial Supervisory Authority, known as BaFin, had articulated its view of conduct in its 2016 annual report, stating “Banks frequently operate in the border zone between legality and legitimacy. Not everything which is legal is also legitimate.”1 In late 2017, BaFin published its minimum requirements for bank’s risk management.2
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