DK-2018-01 · Denmark · 2018
Danske Bank Estonia branch: internal disclosure, Danish FSA orders and a later US resolution
Concerns first raised internally by a bank employee led to a Danish FSA decision containing eight orders and eight reprimands, and to an increase in the bank's capital requirement. The matter was resolved in the United States in 2022.

- Institution
- Danske Bank A/S
- Authority
- Finanstilsynet (Danish FSA)
- Status
- Concluded — resolved 2022
- Theme
- Correspondent banking · AML controls
- Raised by
- Internal employee disclosure, later made public
- Jurisdiction
- Denmark
- Matter arose
- 3 May 2018
- Last recorded
- 13 December 2022
What the sources record
Finanstilsynet issued its decision on the management and control of Danske Bank in connection with the bank's Estonian branch, comprising eight orders and eight reprimands, and indicated a DKK 5bn increase in the capital requirement for compliance and reputational risk.
The disclosure originated inside the bank. The discloser subsequently gave public evidence before the Danish parliament and to European Parliament hearings, describing the opacity of the corporate structures involved.
In December 2022 the bank pleaded guilty in the United States to resolve the long-running investigation into the branch.
Individuals named in this case
Discloser
Howard Wilkinson
Former head of trading, Baltic operations — discloser
Base · Tallinn · London
Raised the Estonia branch concerns internally, later gave public evidence
Reported as the person who first raised the Estonian branch concerns inside the bank, and who subsequently gave evidence to the Danish parliament and to European Parliament hearings.
All individuals in the register →
Primary sources
- Finanstilsynet decision, 3 May 2018
- Reuters — parliamentary hearing, November 2018
- Reuters — guilty plea, December 2022
Questions and answers on this entry
- What does register entry DK-2018-01 record?
- Danske Bank Estonia branch: internal disclosure, Danish FSA orders and a later US resolution. Concerns first raised internally by a bank employee led to a Danish FSA decision containing eight orders and eight reprimands, and to an increase in the bank's capital requirement. The matter was resolved in the United States in 2022.
- Which authority is recorded against Danske Bank A/S?
- The entry is recorded against Finanstilsynet (Danish FSA), in the Denmark jurisdiction, under the theme Correspondent banking · AML controls.
- What is the current status of this entry?
- Status: Concluded — resolved 2022. Last recorded change: 13 December 2022. The matter arose or was first recorded on 3 May 2018.
- How was this matter brought to light?
- Internal employee disclosure, later made public. Each statement in the entry reflects material already published by a named source; nothing beyond those sources is asserted or inferred.
- Where can the primary sources for DK-2018-01 be checked?
- The entry links to Finanstilsynet decision, 3 May 2018; Reuters — parliamentary hearing, November 2018; Reuters — guilty plea, December 2022.
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