On January 8, 2021, the SEC instituted settled cease-and-desist proceedings against Deutsche Bank AG. The Commission stated "This matter concerns the improper use, from at least 2009 through 2016, by Deutsche Bank of third-party intermediaries, business development consultants, and finders (collectively "BDCs") to obtain and retain global business. Hundreds of BDCs were used during this timeframe, and their use was approved by past members of Deutsche Bank's senior management and various regional committees. Among those engaged were foreign officials, their relatives and associates in circumstances where bribery risks were neither assessed nor sufficient steps taken to mitigate bribery risks posed by such engagements . . . As a result of this conduct, Deutsche Bank violated the internal accounting control and books and records provisions of the Foreign Corrupt Practices Act of 1977. During this period approximately $7 million in payments to BDC's were improperly booked as legitimate expenses, and Deutsche Bank was unjustly enriched by approximately $35 million."

The SEC stated: "Deutsche Bank AG will pay more than $43 million to settle charges that it violated the Foreign Corrupt Practices Act (FCPA) in connection with its improper use of third-party intermediaries."

The SEC "announced charges against Deutsche Bank AG for violations of the Foreign Corrupt Practices Act (FCPA). As part of coordinated resolutions with the SEC and the Department of Justice, Deutsche Bank has agreed to pay more than $120 million, which includes more than $43 million to settle the SEC’s charges. "