Compliance Compliance


Compliance Programme

Compliance lays down the correct and law-abiding modus for all business units; adherence to this is the foundation for corporate responsibility. Thus, compliance is an inherent part of risk management in the Commerzbank Group.

As new statutory requirements are continually being put in place and business processes are constantly changing, we are working permanently on the optimisation and further development of compliance-relevant processes.

Commerzbank conducts a systematic, Group-wide risk assessment in all business divisions each year. This assessment forms the basis for the Commerzbank compliance programme. It is a matter of course for us that we implement all the directives and standards of external regulators.

In 2008, Commerzbank, together with Frankfurt School of Finance & Management, developed a degree programme for compliance officers. This part-time programme has made a significant contribution to the professionalization of corporate compliance.

The main focus of our compliance activities is on the preventing and combating of money laundering, the financing of terrorist activities as well as insider trading and fraud. Moreover, we guarantee the security of insider information, other confidential information regarding our clients and their transactions, as well as investor protection. Commerzbank is also committed to prevent human rights and environment-related violations according to the German Supply Chain Due Diligence Act (LkSG).

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Prevention of money laundering and the financing of terrorism

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.

Money laundering and the financing of terrorism are different phenomena. In the case of money laundering, assets from criminal activities are fed into the financial system. In the financing of terrorism, funds from legal sources are used to commit terrorist attacks. Both money laundering and the financing of terrorism need to be prevented in the context of combating international terrorism.

The Know-Your-Customer principle is applied by Commerzbank in order to secure the highest level of transparency on its business relationships and on individual transactions. The Know-Your-Customer principle encompasses the identification and documentation of the client’s identity, as well as the determination of beneficial ownership. Any information received is treated confidentially.

Sanctions and embargos

Compliance ensures that financial and economic sanctions of relevance for Commerzbank, as well as the supplementary regulatory requirements, are observed.
To this end Compliance enacts guidelines and instructions, informs the various Group divisions and subsidiaries on sanctions-related restrictions affecting business policy, advises on implementation and monitors their observation. Should there be business relationships in countries affected by sanctions, Commerzbank monitors these closely and accompanies them with measures, which may even go as far as the termination of business relationships.

Prevention of fraud

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. In this respect, we are pursuing just one goal: we want to protect our clients’ and Commerzbank’s wealth and assets. It is our top priority to shed light on dubious matters and to counter all attempts at white-collar crime without regard for the reputation of the person(s) involved. There can be no tolerance for any such attempts.

This also means that we are open for tips. Clients, employees and third parties can report suspected fraudulent conduct to us at any time.

Managing conflicts of interest

Commerzbank is active in numerous business areas worldwide and is able to offer its clients a wide portfolio of financial services. If the business interests of Commerzbank, its clients or suppliers clash, however, this can also lead to a conflict of interests.

With the objective of avoiding possible conflicts of interest and resolving conflict situations in an appropriate manner, Commerzbank has launched a system for conflict-of-interest management. So as to identify conflict situations in the corporate client segment, for example, Commerzbank utilises a Conflict-of-Interest tool (COI tool). With this COI tool data on the relevant transactions, for example in the corporate client segment or in the capital markets business, are collected worldwide and examined. The standardised approach and documentation also make COI-based decisions transparent and comprehensible for independent third parties.


Corruption comes in many guises and takes place in many different areas. Preventing and combating corruption has the highest priority for the Commerzbank Group.

The Compliance programme to combat corruption addresses employees at Commerzbank and business partners of the Bank. The programme’s objective is to demonstrate how, for example, damage to the assets and image of the Bank through corruption, fraud, embezzlement, breach of trust, cartelisation and money-laundering offences can be avoided. Thus, the Bank ensures that regulations as part of statutory anti-corruption legislation are observed Group-wide.

The prevention of any form of corruption is one point of focus in our compliance activities. Compliance is not restricted to anti-corruption measures, however. Rather compliance requires the responsible conduct of each and every individual, in adherence with all the relevant legislation, voluntary commitments and internal guidelines.

Prevention of human rights and environment-related violations in supply chains according to the German Supply Chain Due Diligence Act (LkSG)

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. To this end, it has written a policy statement (see side box). 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 (see the Complaints Management Rules of Procedure).

Data protection

The trust of our clients is our greatest asset. We therefore take the protection of their personal data extremely seriously. You can find our data protection declaration here.