The report found that during the period, transactions representing a high risk for money laundering were made in the form of payments to customer accounts worth EUR 17.8 billion and payments from customer accounts worth EUR 18.9 billion in the Baltic subsidiaries.

Last week, Sweden’s FSA fined Swedbank a record $385 million over breaches in its anti-money laundering work.

Clifford Chance reports that Swedbank Estonia and Swedbank Latvia actively pursued high-risk customers and Swedbank Estonia accepted certain high-risk customers who had been offboarded as customers in another bank in Estonia, when that bank had decided to discontinue their business with foreign high-risk customers.

Clifford Chance writes that during the period 2007 - 2019, the bank’s senior management failed to establish clear lines of AML-related responsibilities and that Swedbank’s CEO’s throughout the review period all had a lack of adequate appreciation for the risk posed by the high-risk non-resident customers to the bank.

It found that statements from the management team during October 2018 and February 2019 concerning money laundering, "were inaccurate or presented without sufficient context".

Swedbank’s president and CEO Jens Henriksson, comments on the report: “It is obvious that there have been cultures in the bank that are not acceptable. This is serious. I have initiated a review which aims to examine the culture and identify actions needed. This work is under way."

Since last year, new executives have been appointed to a number of central positions, including the bank’s new chairman of the Board, a new vice chairman, a new CEO, a new chief compliance officer and a new chief risk officer.

“Given the information in the investigations conducted by the Swedish and Estonian Financial Supervisory Authorities and ... law firm Clifford Chance, the Board of Swedbank has decided to unilaterally cancel the agreement of severance pay to the bank’s previous CEO Birgitte Bonnesen,” the bank says in a statement.