Germany’s largest bank Deutsche Bank is no stranger to scandals. But the leaked FinCEN files suggest the bank was aware of facilitating suspicious transactions amounting to over $1 trillion dollars, including for a period after it had promised to clean up its act.

The FinCEN files are a huge cache of secret reports detailing suspicious financial activity, filed by banks to the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Treasury Department (USTD).

BuzzFeed News obtained the files and shared them with the International Consortium of Investigative Journalists (ICIJ). Over the past 16 months, 400 journalists from 88 countries have been investigating the documents.

German bank reports over half of all suspicious activity

Deutsche Bank accounts for 62% of all Suspicious Activities Reports (SARs) filed to FinCEN in the leaked documents.

These SARs reflect the concerns of watchdogs within banks and are not necessarily evidence of any criminal conduct or wrongdoing. Financial institutions operating in the US are required to file these reports with the USTD, and failure to do so can result in penalties.

Between 1999 and 2017, $2 trillion (€1.68 trillion) in transactions were flagged by financial institutions’ internal compliance officers as suspicious. Reasons include possibly money laundering, sanctions violations or other criminal activities.

Of these, $1.3 trillion (€1.09 trillion) worth of transactions passed through Deutsche Bank, which reported the activities to FinCEN.

Deutsche Bank previously fined hundreds of millions

This is not the first time Deutsche Bank has been implicated in suspicious money transfers. In 2015 it agreed to a $258 million fine for violating US sanctions.

A probe by US and New York banking regulators found the bank had moved $10.9 billion (€9.2 billion) on behalf of Iranian, Libyan, Syrian, Burmese and Sudanese financial institutions sanctioned by the US between 1999 and 2006. The bank was accused of carrying out transactions for its customers using "non-transparent methods and practices" to disguise its actions.

"Since then we have terminated all business with parties from the countries involved," a Deutsche Bank spokeswoman said at the time.

Continued involvement in suspicious money transfers

The FinCEN Files suggest that Deutsche Bank continued to move money for people and companies deemed suspicious, as indicated by SAR filings from the bank, after the big 2015 settlement.

One case that stands out is that of Reza Zarrab, an Iranian-Turkish gold trader. He pleaded guilty in 2017 in a US federal court to helping Iran evade sanctions.

Deutsche Bank’s US affiliate, Deutsche Bank Trust Company Americas (TCA), submitted an SAR about a company with close ties to Zarrab to FinCEN in March 2017. The report states that the company, Nadir Döviz, which is involved in the gold trade, had more than $28 million (€23 million) transferred in its name.

Deutsche Bank TCA filed its SAR because Nadir Döviz was being investigated for its involvement in a money-laundering scheme. The document says the transactions occurred between March 2016 and February 2017.

In its report, Deutsche Bank stated that the suspicious activities were intra-company payments dispersed between several Turkish banks. "This SAR is being filed because the transactions originated from a high-risk country [Turkey], there were multiple large, round dollar transactions, and no commercial purpose was identified through the transaction details," it reads.

One of these suspicious transactions was for $1.5 million (€1.2 million) from Nadir Döviz in Turkey to Nadir Gold in Dubai on September 12, 2016. No reason was provided for the transfer.

Bank says it ‘learned from mistakes’

Upon receiving a catalogue of detailed questions from ICIJ, a spokesman for Deutsche Bank said the information contained in the files is "not new information to us or our regulators" and that these issues date back to the years prior to 2016, adding that Deutsche Bank is "a different bank now."

In his statement from September 9, the spokesman emphasized: "We acknowledged past weaknesses in our control environment, we apologized for this and accepted our respective fines. Most importantly: we learned from our mistakes, systematically tackled the issues and made changes to our business perimeter, our controls, and our personnel."

The dates of the recorded Suspicious Activity Reports give rise to questions about how much Deutsche Bank knew about Döviz’s connection to Zarrab and the Turkish trader’s involvement in what turned out to be a gold for oil scheme to circumvent sanctions against Iran.

Reza Zarrab’s billion-dollar operation

When Iranian banks were cut off from the global SWIFT transaction system, the country’s companies could no longer use international banking transfers to receive payment for oil and gas exports.

To get around the ban, Iran began collecting gold as payments instead. Reza Zarrab played a key role in this billion-dollar scheme to help Iran evade sanctions.

Zarrab was first indicted and arrested in December 2013 in Turkey, as part of a larger corruption investigation aimed at ministers in the ruling AKP government. Among the charges directed at him were bribing ministers, money laundering and gold smuggling.

According to a report by Turkish prosecutors at the time, Zarrab used Nadir Döviz for buying gold. Zarrab’s bagman Adem Karahan later told Turkish daily Cumhuriyet, that he was a cash courier for money going from Dubai to Turkey and from Dubai to Iran.

One of the companies he received money from was Nadir Gold LLC, a subsidiary of Nadir Döviz in Dubai. It is precisely these two companies that Deutsche Bank lists in its March 2017 Suspicious Activity Report to FinCen.

At the time, the Erdogan administration refuted all allegations against Zarrab and likened the investigation to a coup attempt, purging and arresting the prosecutors who initiated it. After two and a half months in prison, Zarrab was released.

In March 2016 Zarrab was arrested again, this time in the US while on route to Disney World with his family. US authorities accused him of money laundering, fraud and helping the Iranian government to evade the economic sanctions.

He pleaded guilty and later testified as a protected star witness in a trial against a manager of Turkey’s Halkbank.

During this trial in November 2017, Zarrab claimed that Turkish government officials, including President Erdogan, had allowed Halkbank to create a complex web of shell companies and sham transactions in gold to help Iran get around US sanctions.

Nadir Döviz and Deutsche Bank both declined to answer specific questions about their involvement with each other and with Reza Zarrab. But what is apparent is a pattern of Deutsche Bank connections with suspicious customers.

One bank refused, Deutsche Bank moved

The FinCEN Files reveal that Deutsche Bank also conducted transactions for an oil refinery in Turkmenistan, despite it being in possible violation of Iranian sanctions.

Deutsche Bank’s US affiliate filed two SARs in October 2014 and February 2015 related to these transactions.

In these reports, Deutsche Bank states that "Turkmenbashi Oil Processing Complex is still involved in commercial activities restricted under EU sanctions," on the grounds that it exports liquid petroleum gas to Iran. Turkmenbashi Oil is the biggest oil and gas producer in Turkmenistan.

According to the SARs filed by Deutsche Bank TCA, it facilitated transactions worth $168.5 million between April and September 2014 for Turkmenbashi Oil.

It processed nearly $113 million in further transactions between September 2014 and January 2015.

While Deutsche Bank TCA moved money for Turkmenbashi Oil, BNY Mellon, another bank that offers correspondence banking services in New York, refused to process transactions for the company around the same time.

Russian oligarchs under sanctions

The leaked SARs also suggest that Deutsche Bank may have allowed companies to evade sanctions in Russia as well as Iran.

Surgutneftegas is one of Russia’s largest oil companies. It was sanctioned in the US in September 2014 for supporting Russia’s war against Ukraine.

The sanctions forbid providing any equipment or technical support to Russian oil firms, as well as transactions that enable this.

As correspondent bank, Deutsche Bank TCA was involved in 47 transfers amounting to nearly $430 million (€363 million) to and from Surgutneftegas between the beginning of March and mid-May 2015 — well after the announcement of the sanctions.

ICIJ’s analysis of the FinCEN Files indicates that Deutsche Bank also shuffled more than $11 billion in transactions between 2003 and 2017 for companies tied to Oleg Deripaska, a Russian billionaire and a longtime ally of Russian President Vladimir Putin — despite being fully aware of ongoing investigations.

Deutsche Bank itself filed a SAR in November 2016 stating, "Deripaska, is under investigation by US and UK authorities in connection with a $57.5 million wire transfer in 2007."

The report noted that "in the past, authorities in the US have accused Mr. Deripaska of having links to organized crime."

Deripaska was put on the US list of sanctioned individuals in 2018 for money laundering, extortion and links to organized crime groups. He himself denies laundering funds or committing financial crimes and is suing the US government in an effort to reverse the sanctions.

Doing it for the money?

Deutsche Bank has been penalized many times in the past for facilitating suspicious activities. So why would they continue even after the hefty penalty of $258 million in 2015?

For Tim White, a consultant at AML Right Source, an anti-money laundering consulting firm, the answer is simple: Money.

White says that "by going ahead with these suspicious transactions, banks are making more money than the possible cost of the violations."