What evidence supports your correspondent assurance?
A correspondent questionnaire is a representation about actual controls. Group policy cannot substitute for evidence that the relevant branch follows it.
Danske Bank · Intermediate · About 5 minutes
What the official sources say
DOJ announced that Danske Bank pleaded guilty to conspiracy to commit bank fraud in connection with representations to U.S. banks about its Estonia branch’s customers and AML controls. The plea agreement provided for $2.059 billion in criminal forfeiture, with credits for specified parallel payments. [1]
DOJ described a non-resident customer business, shell companies obscuring ownership, and misleading assurances used to retain access to U.S. dollar correspondent services. [1]
The U.S. offence described here is conspiracy to commit bank fraud. The $160 billion processing figure discussed in the source is not proof that every dollar was criminal proceeds. This historical account does not assess current controls.
What to learn from it
Original LearnAML teaching analysis. The following controls and exercises are not additional findings against the named parties.
- Distinguish group policy from evidence of branch-level controls.
- Identify what makes an external control assurance supportable.
- 01Branch exposure
- 02Group assurance
- 03Correspondent decision
- 04Dollar clearing
Simplified LearnAML control map; not a reconstruction of every transaction in the case.
Own the assurance
A correspondent questionnaire is a representation about actual controls. Group policy cannot substitute for evidence that the relevant branch follows it.
Reconcile conflicting records
If an audit identifies material gaps, reconcile those findings with any external assurance. Ask the responsible owner to describe limitations and remediation accurately.
Escalate without concealment
Document the inconsistency and route it to authorised legal and compliance decision-makers. Respect confidentiality while ensuring responses are complete and accurate.
What would you do next?
Fictional exercise: A foreign branch has a high-risk non-resident portfolio. Internal audit reports incomplete ownership records and limited monitoring. A correspondent questionnaire drafted by sales states that all branches meet the group AML standard. The response has not yet been sent.
Put the decision into words
Use fictional details only. Do not enter customer information. Optional saves remain on this device, not your LearnAML account.
Use this checklist to improve your answer. It is not an automatically marked essay.Compare your reasoning
Take one lesson back to work
In your own environment: Test branch-level evidence before making a group-wide control assurance.
Educational analysis, not instructions for a live customer or transaction. Consider your role, authorised procedures and current local requirements.
Sources and editorial record
- DOJ: Danske Bank guilty plea ↗DOJ · 13 December 2022Evidence location: Opening paragraphs and admissions narrative, including plea-agreement terms; Opening paragraphs and admissions narrative, including plea-agreement terms
Sources accessed and educational analysis prepared: 27 October 2026. Historical snapshot; subsequent proceedings, present custody, current controls and present law are not asserted. Original LearnAML educational analysis. Version 1.0.