Howard Wilkinson is a British citizen who attended the University of Oxford, Oxfordshire, England, and studied and graduated in “maths” (mathematics). Wilkinson stated that he “was interested in the financial markets, not least as a good way to use my quantitative skills, so getting a trading job in a bank’s dealing room seemed an interesting place to start my career.” When Wilkinson graduated in 1992, he explained, “It was a terrible time to be starting a career,” given that the world was experiencing a recession.
Successful bankers share common personality traits, and Wilkinson exhibited most of them: good communication skills, mathematical and analytical ability, attention to detail, and strong accounting and finance knowledge. Wilkinson also had an exceptional quality of integrity.
Danske Bank, headquartered in Copenhagen, Denmark, was initially interested in acquiring Sampo Bank in Finland. In November 2006, the Danske Bank purchased Sampo and acquired the Estonia bank that Sampo Bank owned. In 2006, Wilkinson worked at a bank in Finland when an opportunity arose to manage the markets department with Danske Bank in their Estonian branch. He accepted the offer as Baltics head of trading. Wilkinson started working in the Estonia bank weeks after Danske Bank had purchased it.
Wilkinson had nine employees in the markets department, and it traded millions of dollars daily in currency and bonds. Another department generated ninety percent of the Estonian bank profits, and those came from customers termed non-resident depositors. Most of these depositors were Russian and did not live in Estonia.
Five years after joining the Estonian branch of Danske Bank, Wilkinson was asked by an account manager to help with a client who was registered in London. Hundreds of millions of dollars from the client had flowed through the Estonia bank branch in just a matter of months. Upon checking, Wilkinson found that the business records for the London business showed no assets. After Wilkinson notified senior officials at his bank of the discrepancy, he was advised by a bank compliance officer that it was just a clerical error.
A year later, in 2013, Wilkinson found that the client he reported was no longer a client of the Estonian bank branch. However, a bank manager told Wilkinson that the London client was a relative of Vladimir Putin and that the FSB (Russian intelligence) might also be involved in the London account. Meanwhile, at home during Christmas in 2013, Wilkinson wondered about the London business that had moved so much money through the Estonian bank in 2012. Had that company amended its original filing, which showed zero assets? Wilkinson pulled the 2013 report on the Business, and it showed around $20,000 in assets. Wilkinson was aware that current bank records showed the London client was back and had a million dollars on deposit.
A few days after Christmas, Wilkinson emailed Danske Bank officials in Copenhagen and titled the communication “Whistleblowing disclosure-knowingly dealing with criminals in the Estonia branch.” Wilkinson pointed out in the communication that the bank itself may have committed “a criminal offense.” Wilkinson felt that bank executives would investigate and fix the problem, and two days later, a bank executive signaled to Wilkinson that the matter would be investigated immediately.
Wilkinson’s whistleblower warning email was discussed at the Danske’s executive board meeting during the first week of 2014, but Wilkinson was not informed of any action being taken. Wilkinson sent additional communications to Danske Bank senior executives noting that he had checked on more Estonian non-resident bank clients, and all had filed false assets and income reports. Wilkinson stated that an executive at the Estonia branch told him that the bank was “not the police,” and he realized nothing would be done. “Once I’d pulled the amended accounts at Christmas 2013 of the same company I had flagged in Summer 2012 as having filed false accounts, there wasn’t any doubt in my mind it (whistleblowing) was the right thing to do,” Wilkinson realized.
In February of 2014, Estonian inspectors entered the Estonia bank and took thousands of documents. The inspectors sent a blistering report to the Danske Bank in Copenhagen, noting many banking law violations. An internal audit team sent by Danske Bank determined that the Estonian branch had not identified the real source of funds in many accounts and could be aiding money launderers. The audit report was never officially closed.
The head of international banking at Estonian Bank told the Danske Bank auditors that Estonian Bank employees were refraining from noting the actual owners of Russian companies banking with them because they were concerned Russian identities could be exposed to Russian authorities, therefore jeopardizing their clients. The real reason was more akin to the fact that billions of Russian rubles were laundered through the small bank in Estonia, generating millions in profit for the Danske Bank for over a decade.
By March of 2014, Wilkinson had checked additional non-resident clients and found several who had moved millions through the Danske Bank but reported little income. Wilkinson could not get a copy of the internal audit done a month earlier and discovered the audit would not be made official or final. Wilkinson also found out that his managers listened to his phone calls when he was talking to bank auditors. Wilkinson stated that “It was inevitable at that point I would have to resign. I tried to do it in such a way as to put pressure on management to sort things out.”
He emailed his management, advising he had decided to do something else and was leaving. Wilkinson also emailed the Danske Bank chief risk officer and told him Wilkinson would contact authorities if the chief risk officer did not report the false accounts. The risk officer responded that the issues Wilkinson raised would be addressed in Estonia and Copenhagen. Wilkinson ultimately filed four whistleblowing reports to the bank’s internal audit unit and management in Copenhagen before leaving.
When Wilkinson departed the Estonian bank in April of 2014, he signed a Non-Disclosure Agreement and “left on the personal promise of a senior manager (who has since been “preliminarily charged” in Denmark) that the senior manager had zero tolerance for money laundering and would sort out the problems.”
In 2017, a Danish newspaper revealed the money laundering scheme in the Danske Estonian bank, and only at a later date did the Danske bank open an investigation.
Relying heavily on Wilkinson’s original whistleblower disclosures, and the “audit” that was never closed, outside attorneys hired by Danske Bank discovered that the Estonian bank had handled $235 billion in suspicious transactions by non-resident companies, almost exclusively from Russia or former Soviet republics. Most non-resident customers were highly questionable, and the investigation only reviewed half the total 15,000 non-resident clients. Ten banks, including large U.S. and European lenders, help funnel laundered money through Danske banks and out into the financial system. $235 billion is equal to more than all the corporate profits made in Russia in a year. The Estonian branch wasn’t able to identify the source of funds for non-resident clients, a basic banking requirement, and appears to have contributed to a massive money-laundering scheme that involved moving rubles out of Russia, converting them to dollars at the Estonian branch of Danske Bank, and then moving the dollars to New York with the assistance of J.P. Morgan, Bank of America, and Deutsche Bank. Danske Bank admitted that all of its internal controls to prevent money laundering had failed, and a whistleblower had reported the scheme four years earlier.
Wilkinson was “outed” as the Danske Estonian branch whistleblower in 2018 when an “anonymous source” provided his name to an Estonian newspaper. Although that “leak” violated European, Danish and Estonian law, and had to come from wihtin the bank, no European law enforcement agency took any action to investigate the source of the leak or provide protection to Wilkinson. Wilkinson stated that he has “a very good idea who leaked his name, but without an investigation conducted by proper law enforcement authorities, Wilkinson was powerless to protect himself from such bank-related leaks.
“The aim of the leak was, of course, to try to pressure and intimidate me, as you can see, it hasn’t worked.” Wilkinson added, “Clearly, it was not a good time, including my wife’s family back in Estonia. At least here in the U.K. (United Kingdom), we were somewhat insulated. I bought a copy of the Financial Times with a photo of me on the front cover in my local village shop without attracting any comment. After that, there were various further articles in the Danish press to disparage me; curiously, these stopped after the Danish prosecutor preliminarily charged top management and their homes searched. We can only speculate where those stories came from.”
Numerous European law enforcement agencies, along with the U.S. Department of Justice are currently investigating Danske Bank. When asked whether losing his anonymity bothered him, Wilkinson stated, “Yes, because it’s not just about me. It’s about my family and me, for whom obscurity is clearly better. As it is, given that my name has come out, I think I’ve struck a reasonable balance; it’s not as if I have done anything public. It is also important to bear in mind that there are a lot of investigations ongoing; I certainly don’t want to say something publicly that impedes the investigations, so I’m naturally constrained.”
When asked what made him proud of blowing the whistle, Wilkinson stated it was “that my suspicions were vindicated and I really did expose this massive and complicated group of money laundering schemes (it’s not just one scheme).”
The scale of the money laundering scheme startled Wilkinson. “I would probably have guesstimated $40-$50 billion based on what I knew. What I massively underestimated was how much straightforward flow of money in USD (dollars) into customer accounts and money in USD (dollars) out of customer accounts there had been, without any foreign currency component, none of that we saw on my desk, where we were focused largely on foreign exchange,” Wilkinson explained.
When asked about his safety, Wilkinson stated, “We need to be sensible about me and my family’s safety. We certainly have no Russian holidays planned.” Wilkinson also noted, “Anything to do with Russia, and particularly President Putin risks getting hijacked into something political. Let’s focus on the criminality of money laundering and let the investigators go where the evidence takes them.”
Wilkinson noted that “There’s been a lot of excellent reporting on the Danske Bank story. There’s also been a large amount of rubbish printed, including from ‘sources’ who have made things up, selective leaking of documents, opinions of ‘experts’ and such like.” Wilkinson continued, “I read recently that I blew the whistle because I was disillusioned that my team’s most profitable client had been closed down for AML [Anti-Money Laundering, policies and pieces of legislation that force financial institutions to monitor and to follow anti-money laundering regulations] reasons. The ‘source’ was a former member of my team. One slight problem, the client in question, wasn’t the most profitable client. In fact, it wasn’t even close to being the most profitable client, as I think former members of my team would know. With ‘sources’ like that, who needs facts?”
Asked to comment on the rumor that Wilkinson is “stubborn,” he responded, “I’m probably not the easiest person in the world to get to do something I don’t want to do, so ‘stubborn’ isn’t totally unfair.” Wilkinson stated of the top management at Danske Bank, “I am not going to comment on the bank’s former top management. However, speaking more broadly, I think a greater degree of personal accountability (both criminal and civil) by top management in banks, including large international banks and ‘national champion’ banks, than we have seen during my banking career, would be beneficial in improving conduct.” Wilkinson stated that “The same top management in large part has been ‘preliminarily charged’ by the Danish prosecutor (like being a formal suspect). It will be interesting to see if they ultimately stand trial. In the circumstances, it would not be appropriate to give my opinion on them.”
Wilkinson was asked what advice he would give to other whistleblowers, and he responded, “They need to balance their desire to do the right thing with watching out for themselves and their families. The legal environment for whistleblowers is improving, but whistleblowers still need to take care. Get a lawyer who is an expert in whistleblower law or at least get help from one of the whistleblower support groups such as the National Whistleblower Center. And having decided to blow the whistle, gather as much information as possible. Please write it down in as much detail as possible. That way, you help the investigators as much as possible, which, after all, is the whole point of whistleblowing.”
Wilkinson hopes that law enforcement authorities, such as the U.S. Department of Justice, “close as many of the money laundering schemes, catch as many of the money launderers and recover as much laundered money as possible. Also raise the standards in correspondent banks in the United States, who ultimately let all the money out into the financial system, pristine and white.” Wilkinson stated that he feels “good” about shutting down a multibillion-dollar money laundering pipeline. He knows that it will “count as real impact.”
Wilkinson does not see himself as a hero: “No, I see myself as a citizen. As citizens, we entrust our government, our police and prosecutors, even our banks and their regulators with the responsibility to dissuade, identify and prosecute money laundering and other crime. But we don’t abrogate all responsibility; sometimes, as citizens, we have to do our part too. That’s what I see myself as having done, which was clearly the right thing to do in the circumstances.”
Wilkinson stated that “It’s now six and a half years since I left the bank; I’m looking forward to this all being over! Meaning the investigations are complete, any criminal and civil actions complete. No need ever to think about Danske Bank again. I haven’t thought much about what comes after that, to be honest.”
Wilkinson stated that he is “comfortable, satisfied with the outcome of my whistleblowing (so far) and very much enjoying working with, and being represented by my fantastic attorney, Steve Kohn, who has spent his whole career representing whistleblowers and no one else.”
Stephen M. Kohn, who represented Howard Wilkinson during his whistleblower case and in testimony before the European Parliament and Danish Parliament, explained that “Money laundering is a cancer on democracy. Whistleblowers like Howard Wilkinson are the cure. Whistleblowers should not have to lose their careers and risk the safety of themselves and their families when pointing out how the largest banks in the world facilitate terrorist financing, bribery, and corruption.”
Wilkinson is currently under consideration for the prestigious Allard Prize for International Integrity. The ceremony will be on October 21, 2020.