The New York Department of Financial Services issued a consent order fining Nordea Bank Abp $35 million on 27 August 2024, finding that the Finnish-headquartered Nordic bank had maintained material deficiencies in its anti-money laundering compliance programme, with particular failures identified at the bank's former Baltic branches and its former International Branch in Vesterport, Denmark. The action by the DFS, which supervises financial institutions operating in New York State, concludes its investigation into Nordea's AML controls.
Nordea confirmed the resolution in a public statement on 27 August 2024, acknowledging that the matter related to what it described as old AML procedures. The consent order sets out the deficiencies identified and the $35 million civil monetary penalty Nordea has agreed to pay.
BALTIC BRANCHES AND CORRESPONDENT BANKING AT THE CENTRE
DFS investigators found deficiencies in Nordea's AML programme specifically at its former Baltic branches and its now-closed International Branch in Vesterport, Denmark.
Among the specific failures identified by the DFS was Nordea's inadequate due diligence on correspondent banking relationships — the arrangements under which one bank processes international payments on behalf of another. The DFS found that Nordea's controls in this area fell short of the standards required.
The consent order also addressed conduct related to the Panama Papers, the large-scale leak of documents from the Panamanian law firm Mossack Fonseca that revealed the use of offshore structures by a wide range of individuals and entities. Nordea, along with several other European financial institutions, was identified in connection with clients and structures disclosed in those documents.
NORDIC REGULATORS HAD PREVIOUSLY FLAGGED CONCERNS
The DFS action follows earlier scrutiny of Nordea's AML programme by Nordic financial supervisory authorities including those of Finland, Sweden, Denmark, and Norway, all of which had previously flagged weaknesses in the bank's anti-money laundering arrangements.