Compliance

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Proactive compliance risk management

With a view to the regulatory environment, compliance identifies upcoming risks and challenges and actively manages them in line with the Group's risk appetite and strategic goals. The focus is on the prevention of money laundering, terrorist financing, insider trading, fraud, corruption, and other criminal activities as well as ensuring sanctions, embargos, and markets compliance are observed in the context of our business activities. In addition, compliance focuses on addressing human rights and environmental risks in the Bank's supply chains in accordance with the principles set out in Commerzbank’s Human Rights Position.

Anti-Money Laundering and Counter Terrorist Financing

One of the core tasks of compliance is meeting regulatory requirements intended to prevent and combat money laundering and the financing of terrorism. In addition to national requirements and industry standards, Commerzbank complies with established international standards such as the Financial Action Task Force (FATF) recommendations and the Wolfsberg Anti-Money Laundering Principles .

Sanctions and embargos

Compliance ensures that financial and economic sanctions of relevance for Commerzbank, as well as the supplementary regulatory requirements, are observed.

Markets Compliance

Compliance is responsible for the early detection of compliance risks in the provision of investment services and securities ancillary services that could jeopardise the integrity and, therefore, the success of the Bank. By controlling these risks, they will be adequately reduced and, if possible, prevented in the interests of all parties involved.

Fraud prevention and anti-corruption

The Commerzbank Group takes extensive precautions so that clients and employees do not become the victim of or a part of fraudulent acts. Moreover, we protect our products and processes against misuse. In all areas we emphatically advocate preventive anti-fraud measures. We have defined comprehensive measures so as to prevent, uncover, and adequately respond to white-collar crime. Commerzbank is persuing a zero-tolerance policy for any such crimes.

Human rights and environmental due diligence obligations

Commerzbank is aware of its corporate responsibility to respect human and environmental rights. It therefore undertakes to respect these in its own business area and in its supply chain and to give those affected by human rights and environmental law violations access to remedies. Anyone who is potentially affected by human rights or environmental law violations within Commerzbank AG or within the supply chains can submit information via the whistleblowing system, regardless of whether this happens in Germany or abroad.

Further information to human rights and environmental due diligence obligations

Policy Statement of Commerzbank AG on human rights and environmental due diligence (pdf, 248 KB)

Code of Procedure - Complaints Process (pdf, 182 KB)

Conflict of interest management

Commerzbank is active in numerous business areas worldwide and can offer its customers a large portfolio of financial services. However, when Commerzbank, its customers, or suppliers face business interests, this can also lead to conflict situations. With the aim of avoiding potential conflicts of interest and resolving conflict situations appropriately, Commerzbank has introduced a system for conflict of interest management. For example, Commerzbank uses a conflict-of-interest tool (COI tool) in its business with corporate customers. The standardised procedure and documentation also make COI-based decisions transparent and comprehensible for independent third parties.

Conflicts of Interest (client information) - only German version (pdf, 316 KB)

Your help is needed

Whistleblowing system

The Commerzbank Group is committed to integrity in its corporate values and seeks open communication with its customers, employees and third parties. We are strongly committed to preventing and punishing wrongdoings. If you have any indications of violations of legal, regulatory or internal requirements in connection with Commerzbank, we would like to encourage you to send us your report via the whistleblowing system (Business Keeper Monitoring System - BKMS). Reports regarding adverse impacts related to human rights and the environment in our supply chain according to the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz - LkSG) should also be submitted hereby. You can file your report by name or anonymously. In any case, we will treat your information strictly confidential and take into account the legitimate interests of all parties involved within the scope of the legal possibilities

UK Tax Strategy

We are committed to complying with UK tax obligations, and we operate within the Commerzbank Group’s policies. We are committed to ensuring that we pay the right amount of all UK taxes and that all UK tax returns are completed accurately and on time.

Download the strategy (pdf, 219 KB)

USA PATRIOT Act

Commerzbank AG has renewed its certifications in accordance with the USA PATRIOT Act as of 9 May 2014.
The USA PATRIOT (Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism) Act, signed into law by President George W. Bush in October 2001, requires financial institutions to put in place stringent compliance programmes regarding the activities of a broader range of account holders than ever required before.
Commerzbank AG certifies the compliance with the USA PATRIOT Act. The certification is available in PDF. In order to print or view it, you must have the Adobe Acrobat Reader installed on your computer.

Special note on Commerzbank AG's Grand Cayman branch
The Grand Cayman branch of Commerzbank AG does not maintain a physical presence or staff on the Cayman Islands. The branch is managed by Commerzbank AG North America, New York, United States of America.
The branch maintains a banking license issued by the Cayman Monetary Authority and is regulated and under supervision of the Cayman Monetary Authority.
Please note: The Grand Cayman branch is included under Commerzbank AG's certification to the USA PATRIOT Act.

More information

Blank Patriot Act Form (pdf, 217 KB)