Broker-dealers are required by the Bank Secrecy Act and regulations promulgated by the U.S Department of the Treasury’s Financial Crimes Enforcement Network to file SARs for transactions they have reason to suspect involve funds derived from illegal activity, lack a business or apparent lawful purpose, or are intended to facilitate criminal activity.

According to the SEC, Deutsche Bank Securities received requests in connection with law enforcement or regulatory investigations or litigation that prompted it to conduct SARs investigations. However, the SEC says,, in certain instances from April 2019 to March 2024, Deutsche Bank Securities failed to conduct or complete the investigations within a reasonable period of time, including at least two instances where Deutsche Bank Securities took more than two years to file the SARs.

“Even the best information collected from SARs is of limited use if its stale by the time it’s provided to law enforcement,” said Sheldon L. Pollock, Associate Director of the SEC’s New York Regional Office. “Through this enforcement action, we are not only holding Deutsche Bank Securities accountable, we are also sending a clear message to other market registrants that timeliness in filing SARs is of paramount importance.”

There seems to be no concern as to duplication with other agencies or as to over-reach.

The SEC said that Deutsche Bank Securities breached Section 17(a) of the Securities Exchange Act and Rule 17a-8 thereunder. Without admitting or denying the SEC’s findings, Deutsche Bank Securities agreed to a censure, a cease-and-desist order,and the civil penalty referenced above.