Boies Schiller Flexner partners Lee Wolosky and Dawn Smalls will serve as independent monitors for Deutsche Bank after it was accused in recent years of doing business on behalf of countries sanctioned by the United States and allowing billions of dollars to move out of Russia, sources have told ALM.

The monitorship is the result of two consent orders Deutsche Bank entered into with the New York State Department of Financial Services in 2015 and 2017 over the allegations.

Wolosky and Smalls will be responsible for monitoring compliance by Deutsche Bank of the two consent orders, which included remediation efforts and programs to address the sanctions previously brought against the institution by DFS.

The first was entered to settle allegations that the bank used several non-transparent methods and practices to conduct more than 27,000 transactions on behalf of countries and entities sanctioned by the U.S., including Iran, Libya, Syria, Myanmar and Sudan.

Those transactions were geared by employees of the bank to avoid detection by entities in the U.S., and avoid added scrutiny by regulators. They were valued in the aggregate at approximately $10.86 billion. Deutsche Bank paid $258 million to settle the allegations.

The second was entered into with the agency after Deutsche Bank was accused of allowing clients to engage in a so-called "mirror trading" scheme that allegedly laundered $10 billion out of Russia.

Certain clients of the bank had engaged in a scheme of issuing orders to the Moscow branch for stock in Russian companies, paying in rubles, and then selling that stock through Deutsche Bank's London branch.

An investigation by DFS found the bank missed several opportunities to detect—and stop—the money laundering scheme. Deutsche Bank was fined $425 million over the violation.

After those violations, Deutsche Bank agreed to review its corporate governance structure and take corrective measures to prevent employees of the institution from engaging in the same kind of conduct in the future.

It's unclear how long Wolosky and Smalls will stay on as independent monitors of the bank's compliance with the consent orders. The 2017 consent order said such a monitor would remain for two years, but sources said their tenure may extend past that mark.

Representatives for DFS, Deutsche Bank and the law firm declined to comment on the selection of Wolosky and Smalls as monitors.

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