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https://www.nasdaq.com/articles/deutsche-banks-dws-to-pay-$25-mln-penalty-for-anti-money-laundering-and-esg-violations-:

Investment adviser DWS Investment Management Americas Inc, a subsidiary of Deutsche Bank AG (DB), agreed to pay $25 million to settle civil charges that it made misstatements regarding its Environmental, Social, and Governance or ESG investment process and failed to develop a mutual fund anti-money-laundering program.

The U.S. Securities and Exchange Commission's order found that DWS caused mutual funds it advised to fail to develop and implement a reasonably designed Anti-Money Laundering program to comply with the Bank Secrecy Act and applicable Financial Crimes Enforcement Network regulations.

The order also found that DWS caused such mutual funds' failure to adopt and implement policies and procedures reasonably designed to detect activities indicative of money laundering and to conduct Anti-Money Laundering training specific to the mutual funds' business.

In the second enforcement action, the SEC's order found that DWS made materially misleading statements about its controls for incorporating ESG factors into research and investment recommendations for ESG integrated products, including certain actively managed mutual funds and separately managed accounts.

The order found that DWS marketed itself as a leader in ESG that adhered to specific policies for integrating ESG considerations into its investments; however, from August 2018 until late 2021, DWS failed to adequately implement certain provisions of its global ESG integration policy as it had led clients and investors to believe it would.

The order found that DWS also failed to adopt and implement policies and procedures reasonably designed to ensure that its public statements about the ESG integrated products were accurate.