BaFin Orders Deposit-Taking Business to Cease
The Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin, German Federal Financial Supervisory Authority) has ordered D F S BANK BROKERS CO. L.L.C, which is based in Dubai in the United Arab Emirates, to immediately cease and promptly wind up the deposit-taking business it operated in Germany without authorisation. According to BaFin, the company also operates under the name “DEECKE Bank Brokers L.L.C”.
The underlying BaFin administrative order is dated 24 April 2026 and is final and binding. The authority published its related notice on 28 October 2026.
Acceptance of Funds Subject to an Unconditional Repayment Obligation
According to BaFin’s findings, D F S BANK BROKERS CO. L.L.C accepted funds in Germany that were subject to an unconditional repayment obligation. The respective repayment claim was not securitised in transferable bearer or order debt securities falling within the exemption under § 1 Abs. 1 Satz 2 Nr. 1 Kreditwesengesetz (KWG, German Banking Act).
The contracts concerned subscriptions for “bearer partial debentures” from the following series:
- The contracts related to the T2024-2029 series.
- The T2025-2027 and T2025-2030 series were also covered.
- The findings additionally concerned the 2024-2029 and 2025-2030 series.
BaFin classified this activity as deposit-taking business within the meaning of § 1 Abs. 1 Satz 2 Nr. 1 KWG. According to the authority’s findings, D F S BANK BROKERS CO. L.L.C did not hold the required authorisation from BaFin.
Prompt Repayment of the Funds Accepted
The winding-up order requires D F S BANK BROKERS CO. L.L.C to promptly repay the funds it accepted. In addition to the immediate cessation of the unauthorised deposit-taking business, the order therefore also covers its winding-up.
Notification to Companies Based Abroad
For administrative acts addressed to companies based outside Germany, § 4h Finanzdienstleistungsaufsichtsgesetz (FinDAG, German Financial Services Supervision Act) contains special provisions. If a foreign company has not appointed an authorised representative in Germany, BaFin administrative acts may, subject to the statutory requirements, be announced or served by publication in the Bundesanzeiger (German Federal Gazette).
Further BaFin Proceedings Against a Company with a Similar Name
By an administrative order dated 26 February 2026, BaFin had already ordered DFS – Asset Management GmbH, a similarly named company based in Munich and formerly based in Mannheim, to cease and wind up deposit-taking business conducted without authorisation. According to the authority, this company also operates as “DFS – Die Finanzstrategen”.
In these separate proceedings, the T2024-2029 and T2025-2030 series were among those covered by the authority’s findings. Both series are also referred to in the order against D F S BANK BROKERS CO. L.L.C. This does not establish any corporate or personal connection between the two companies.
Assessment from a Banking Law Perspective
Whether banking business requires authorisation depends on the specific structure of the contracts offered and the repayment claims created by them. The designation given to a contract or financial instrument is not, by itself, decisive for its regulatory classification.
Companies, investors and high-net-worth individuals seeking advice on deposit-taking business requiring authorisation, regulatory winding-up orders and the associated contractual relationships can obtain banking law advice from MTR Legal Rechtsanwälte.
