Administrative fine imposed on CCV for inadequate customer due diligence

Payment institutions act as gatekeepers to the financial system under the Wwft. Among other things, they must continuously monitor transactions, detect unusual transactions and report them to the Financial Intelligence Unit (FIU-NL) without delay. This is essential to prevent misuse of the financial system, as malicious parties can use the services of payment institutions to launder money of criminal origin. Once customers are accepted, payment institutions have an obligation to monitor all transactions carried out by or on behalf of these customers on an ongoing basis. Failure to comply with this obligation undermines the integrity of the financial system. We therefore impose fines to emphasise the importance of proper compliance.

Non-compliance

Based on our examinations we found that CCV has not sufficiently complied with its obligation to continuously monitor transactions. This means CCV is in non-compliance with Section 3(2) of the Wwft. CCV’s transaction monitoring system did not function properly for a prolonged period; for over two years, the system was not fully and htimely fed with all transactions from CCV’s merchants. CCV also failed to properly load transaction profiles into the transaction monitoring system for 4,200 merchants (about 8% of the total number of merchants) for 23 months. In addition, we found that CCV did not perform adequate ongoing monitoring of the majority of alerts we reviewed. For example, CCV did not sufficiently motivate why alerts were closed, or forwarded alerts to a department that failed to review them. CCV closed transactions 'in bulk' without further justification, and relevant integrity risks were not sufficiently examined as a result.

Because we had previously imposed an administrative fine on CCV for non-compliance with Section 3(2) of the Wwft, we increased the basic fine amount of €2.5 million. We subsequently revised the fine amount downwards because of CCV's recovery plan which CCV submitted and is implementing.

Read the full decision below (in Dutch), excluding confidential information. For further information, please contact DNB’s Information Desk at telephone number 0800 - 020 1068 (free of charge) or +31 20 524 9111 (if calling from abroad).

Current status

A decision becomes final if no legal remedy has been exercised against it. Any interested party may lodge an objection against the decision within six weeks of its date. The decision on the objection can be appealed in court within six weeks. Further appeal against the court ruling may be lodged with the Trade and Industry Appeals Tribunal (College van Beroep voor het bedrijfsleven – CBb). If no objection, appeal or further appeal is lodged, the decision becomes irrevocable. The table shows the current status of this decision.