Money laundering and the financing of terrorism pose considerable sociopolitical risks. For this reason, the prevention of money laundering and the implementation of anti-money laundering measures have been defined as central compliance goals in our Integrity Code. In its core business, the global production and sale of vehicles, Daimler AG and its Group companies conduct their operations in accordance with the provisions of the German Money Laundering Act (GwG), which apply to “distributors of goods.” As a result, we are required to implement Group-wide and thus worldwide measures to prevent and combat money laundering and the financing of terrorism (Anti-Money Laundering - AML - and Counter Terrorist Financing - CTF - policies).
The Chief Compliance Officer officially serves as the Group Anti-Money Laundering Officer of Daimler AG in its role as a distributor of goods. The Chief Compliance Officer reports directly to the Board of Management and also serves as the point of contact for regulatory authorities, law enforcement agencies, authorities responsible for the prevention, investigation, and elimination of potential threats, and Germany’s Financial Intelligence Unit. In his capacity as the Anti-Money Laundering Officer, the Chief Compliance Officer has sufficient authority and means to perform his duties.
Daimler AG and its Group companies pursue an integrated compliance approach in all areas of the Group and around the world. This approach takes the form of a central Group unit, “Anti-Financial Crime,” and ensures that checks against sanctions lists are always carried out before Anti-Money Laundering measures are implemented. This integrated approach links prevention of the circumvention of supranational and national sanctions with measures to prevent and combat money laundering, the financing of terrorism, organized crime, and other corporate crime. This is important, as these risks can not only have a negative impact on society; they can also cause long-term damage to our reputation, as well as financial damage that can negatively affect our Group companies and our shareholders and stakeholders.
The Anti-Financial Crime specialist unit assists the Anti-Money Laundering Officer by acting as the Group organization for ensuring that Daimler AG and Group companies comply with the provisions of the GwG across all divisions in their role as distributors of goods. The unit is also responsible for the Group-wide Sanctions Compliance Program. As a central Group organization, the specialist unit therefore also brings together under one roof our two Centers of Competence for Preventing and Combating Money Laundering and the Financing of Terrorism and the Center of Competence for Sanctions Compliance.
The Daimler AG Sanctions Compliance Program, which is valid for all Group companies, includes systematic reviews of compliance with sanctions lists by all units, divisions, and companies worldwide. More specifically, such reviews check whether the names of affected natural persons or legal entities can be found on any sanctions list around the globe. We therefore check both supranational sanctions lists such as those published by the United Nations and the European Union and national sanctions lists from various countries, in particular the United States. As required by law, such reviews are conducted for customers and business partners, for example in sales and procurement, as well as for employees and strategic cooperation partners. Checks against sanctions lists, which are performed in close cooperation with the Export Control department, take data protection law provisions into account.
Measures to combat money laundering and the financing of terrorists are defined for Daimler Mobility AG (DMO) and the Group companies that belong to it by a separate framework divisional guideline that also serves as a basis for the policies at DMO companies. An independent network of local Anti-Money Laundering (AML) Officers has also been established for the individual Group companies allocated to DMO.