Samherji notes that the Norwegian bank DNB has received a violation penalty from the Norwegian supervisory body Finanstilsynet of 400 million Norwegian kroner. Samherji has no knowledge of this violation penalty beyond what may be read in publicly available sources.

As far as we can see from the case documents, this violation penalty stems from an ordinary anti-money-laundering inspection against DNB in February last year. The conclusion is apparently that DNB's general systems and work to detect money-laundering have been insufficient. Similar inspections have led to violation penalties also for smaller Norwegian banks. DNB has explicitly stated publicly that Finanstilsynet does not accuse them of having aided customers in laundering money, but rather they are accused of generally not following the detailed Norwegian legal framework for anti-money-laundering efforts.

We further note that Finanstilsynet has made a special report about DNB's relationship to Samherji. We have three brief comments to this report:

First, although the report focuses on DNB's relationship to Samherji, this report is too focused on DNB's own routines in light of Norwegian legislation.

Secondly, the report is inaccurate. That is not a surprise since Samherji has never been contacted or asked one single question by Finanstilsynet. Again, this is probably because Samherji is not a party to this matter. Still, it is of course very unfortunate that a report concerning a third party's confidential client information, containing so many inaccuracies, is made public without the company mentioned in the report being given the opportunity to comment. All these inaccuracies have also resulted in even more inaccurate and distorted news reporting. One of many examples is the impression left that all payments through DNB accounts were related to Namibia. That is certainly far from correct, the vast majority of transactions related to sale of fish and vessels around the world; transactions that were completely uncontroversial.

Thirdly, this report – or DNB's relationship to Samherji – does not particularly impact the matter between DNB and Finanstilsynet. The violation penalty given to DNB today is exactly the same as what was announced as a general violation penalty against DNB already in December. Also, Finanstilsynet explicitly states that Samherji is probably not a unique matter for DNB. The fine is apparently given for lacking routines in relation to as many as 400 customers, Samherji merely being one of those 400 customers.

Samherji has spent significant resources on getting to the bottom of the relevant facts in this matter. We are prepared to explain ourselves in any relevant forum should this become relevant. Two years since news broke about the so-called Fishrot case, no Samherji individual or company is charged. We will respond accordingly should we be contacted by appropriate authorities.