Anti-Money Laundering Enforcement Developments in the Netherlands

Introduction and background

After previous administrative enforcement sanctions against major Dutch banks such as ING ABN AMRO and Rabobank the Dutch Central Bank (DNB) the key regulator in the oversight of the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act has shifted its focus to smaller financial institutions. While the Dutch Public Prosecution Service (DPPS) continues to take criminal enforcement action against financial institutions DNB is breaking new ground with a revised approach to the fight against money laundering in the financial sector containing a more risk-based approach and more practical guidance to financial institutions to better fulfil their role as gatekeepers. This briefing provides an overview of recent enforcement developments and policy changes in the Netherlands that may be of interest to (foreign) legal practitioners and other stakeholders within financial institutions.

Instruction for de Volksbank

In August 2023...