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ARTICLE · 17 JULY 2026

How To Avoid A Trade Reporting Fine In 6 Steps

ASIC recently issued an infringement notice to Deutsche Bank Aktiengesellschaft (Deutsche Bank), which paid a penalty of $2 million for misreporting more than 260,000 over-the-counter (OTC) derivative transactions. This is a step-change in scale for ASIC trade reporting enforcement – roughly four times the combined AMP Life/AMP Capital penalties ($526,000, 2020) and more than fifteen times the Westpac penalty ($127,250, 2017), both issued under the earlier reporting rules regime.

AustraliaFinance and Banking

Background

ASIC recently issued an infringement notice to Deutsche Bank Aktiengesellschaft (Deutsche Bank), which paid a penalty of $2 million for misreporting more than 260,000 over-the-counter (OTC) derivative transactions. This is a step-change in scale for ASIC trade reporting enforcement – roughly four times the combined AMP Life/AMP Capital penalties ($526,000, 2020) and more than fifteen times the Westpac penalty ($127,250, 2017), both issued under the earlier reporting rules regime.

Deutsche Bank – Summary of alleged contraventions

Between 21 October 2024 and 15 August 2025, across 208 separate business days, Deutsche Bank:

  • failed to take all reasonable steps to accurately report the mandatory ‘direction’ field which identifies whether the reporting entity is the effective buyer or seller of a transaction at a specified price for 20,483 outstanding transactions and 244,091 terminated or matured transactions, relating to foreign exchange and commodities OTC derivatives;

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