Search of Deutsche Bank Headquarters: Prosecutors Investigate Former Postbank's Cum-Cum Deals

According to information from "Business Insider" and "Welt" as well as the research network of Süddeutsche Zeitung, NDR and WDR, the background to the searches is investigations into so-called Cum-Cum deals. The Düsseldorf public prosecutor's office stated that the Central and Contact Point for the Prosecution of Economic and Financial Crime is conducting an investigation in which searches were carried out on Wednesday in Frankfurt and other locations. The authority provided no further information, citing tax secrecy.

The role of the former Postbank

As the Süddeutsche Zeitung reports, the focus of the investigations is not Deutsche Bank but the former Postbank. The DAX-listed group acquired a stake in the Bonn-based institution in 2008, secured a majority of shares in 2010, and finally fully legally integrated Postbank in 2018. Deutsche Bank had taken over Postbank in 2009 and is thus considered its legitimate successor organization.

Specifically, according to information from the investigators, the matter concerns the so-called "Riesling" project, in which questionable tax deals are alleged to have been made between 2008 and 2010. The investigators assume a tax damage of more than 350 million euros, which may have been caused by false or incomplete corporate income tax returns. According to information from SZ, NDR and WDR, the Düsseldorf public prosecutor's office lists ten former top managers of Postbank as accused in the specific case.

In Cum-Cum deals, the actors exploited the fact that taxation for tax residents was lower than for non-tax residents until 2013. Cum-Cum deals are stock transactions around the day of dividend distribution. Shares were temporarily transferred to domestic banks or funds, which – unlike foreign investors – could have the withholding tax owed refunded. While Cum-Ex involved the refunding of withholding tax that had never been paid in the first place, banks in Cum-Cum deals generated tax advantages for foreign holders of German shares.

How Cum-Cum deals work

Unlike the Cum-Ex transactions, which have been classified as punishable, Cum-Cum models are not fundamentally illegal. However, authorities and courts have been examining for years whether many of these constructions were unlawful and whether taxes were saved unduly. Although the Federal Fiscal Court had already ruled in 2015 that Cum-Cum deals in certain forms were not lawful, the financial authorities have so far only recovered a small portion of the funds.

Mannheim-based professor of taxation Christoph Spengel estimates the potential nationwide damage from Cum-Cum deals at around 28 billion euros overall – far higher than from Cum-Ex deals. The federal government puts the damage at 7.3 billion euros. In the specific Postbank complex alone, tax damage of more than 350 million euros is said to have occurred.

According to research by SZ and WDR, the Cologne public prosecutor's office has already been investigating for several years on suspicion that Deutsche Bank may have collected more than 600 million euros from deals between 2009 and 2015 that actually belong in the state coffers. As early as March 2026, research by SZ and WDR had shown that Deutsche Bank itself may also have been involved on a large scale in Cum-Cum deals.

Extent of the tax damage

Deutsche Bank had already received several visits from the public prosecutor's office this year. Just the week before, the Frankfurt public prosecutor's office had confirmed a raid on a branch of Deutsche Bank at Frankfurt's Taunusanlage; however, it did not comment on the exact background. Officers from the public prosecutor's office and the tax investigation unit were deployed at the headquarters on Wednesday.

Deutsche Bank's share was trading via XETRA at times 0.58 percent higher at 31.25 euros. A statement from Deutsche Bank on the specific allegations was not initially available. However, the bank pledged to "fully" cooperate with the authorities.

The public prosecutor's office emphasized that the ongoing investigation is directed against natural persons, namely former top managers of Postbank. Deutsche Bank is being searched as a third party because, as Postbank's legal successor, it is responsible for the documents. The Frankfurt-based group thus bears no direct criminal responsibility for the deals at the time, but as the current owner of the documents must tolerate and support the investigations.

Possible consequences for the accused

If the suspicion of tax evasion is confirmed, the accused face a prison sentence of up to ten years, and in particularly serious cases up to 15 years. The investigators are currently evaluating data material, emails and internal presentations to clarify the role of the individual managers in the "Riesling" project. When the Düsseldorf public prosecutor's office expects initial results is unclear.

Financial experts see the renewed large-scale raid on Deutsche Bank as a sign that the judiciary is pursuing Cum-Cum constructions with high intensity. BaFin is also monitoring the proceedings; a statement from the supervisory authority is pending. Observers expect that other banks will have to reckon with searches in the coming months.

Political and regulatory reactions

The Düsseldorf public prosecutor's office has so far made neither the names of the accused nor the specific charges public. Deutsche Bank referred to ongoing investigations and did not comment on individual managers or business transactions. It therefore remains open how many of the former Postbank managers will actually be charged and what role the management level at the time played.

Overall, the incident underscores the political explosiveness of the Cum-Cum affair. The federal and state governments had recently stressed on several occasions that they want to pursue tax arrangements of this kind more consistently. A report by the Conference of Finance Ministers, which takes stock of the processing to date and contains recommendations for legislative changes, is expected by the end of the year.