Defendant Name: DWS Investment Management Americas, Inc.

Defendant Type: Subsidiary of Public Company
Public Company Parent: Deutsche Bank AG
SIC Code: 6029
CUSIP: D1819089

Initial Case Details

Legal Case Name In the Matter of DWS Investment Management Americas, Inc.
First Document Date 25-Sep-2023
Initial Filing Format Administrative Action
File Number 3-21709
Allegation Type Investment Advisers/Investment Companies

Violations Alleged

Other
• Sections 206(2), 206(4) Advisers Act; Rules 206(4)-7 and 206(4)-8 Advisers Act

Resolutions

First Resolution Date 25-Sep-2023
Headline Total Penalty and Disgorgement $19,000,000

Related Documents:

IA-6432 25-Sep-2023 Administrative Proceeding
Order Instituting Administrative and Cease-and-Desist Proceedings, Pursuant to Sections 203(e) and 203(k) of the Investment Advisers Act of 1940, Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order
On September 25, 2023, the SEC instituted settled administrative and cease-and-desist proceedings against DWS Investment Management Americas, Inc., stating: "This matter arises from DWS Investment Management Americas, Inc.’s (“DIMA”) material misstatements, and its failure to adopt and implement policies and procedures reasonably designed to prevent the resulting violations of the Advisers Act and the rules thereunder concerning DIMA’s integration of Environmental, Social, and Governance (“ESG”) factors in research and investment recommendations for certain actively managed ESG integrated mutual funds and separately managed account strategies advised by DIMA (collectively the “ESG Integrated Products”)."
2023-194_3-21709 25-Sep-2023 Press Release--Administrative Proceeding
Deutsche Bank Subsidiary DWS to Pay $25 Million for Anti-Money Laundering Violations and Misstatements Regarding ESG Investments
On September 25, 2023, the SEC stated that: "[It] charged registered investment adviser DWS Investment Management Americas Inc. (DIMA or DWS), a subsidiary of Deutsche Bank AG, in two separate enforcement actions, one addressing its failure to develop a mutual fund Anti-Money Laundering (AML) program, and the other concerning misstatements regarding its Environmental, Social, and Governance (ESG) investment process. To settle the charges, DIMA agreed to pay a total of $25 million in penalties."