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Fine for ABN AMRO Bank N.V. for inadequate customer due diligence for high-risk customers

Enforcement measures

De Nederlandsche Bank (DNB) imposed an administrative fine of €8.5 million on ABN AMRO Bank N.V. (ABN AMRO) on 6 July 2026 due to serious shortcomings in its anti-money laundering controls in the period from September 2023 through September 2024. DNB identified structural shortcomings in the performance of ongoing monitoring for a portion of its high-risk customers. In its fining decision, DNB illustrated these shortcomings by referring to five customer files.

Published: 09 July 2026

Singelgracht met boot

Key elements of the fining decision

  • Banks play a crucial role in the fight against subversive crime because of their unique access to financial information and transaction flows. This is precisely why it is essential that they implement effective anti-money laundering controls to keep the financial sector clean.

  • DNB’s enforcement approach is aimed at ensuring compliance with the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en terrorismefinanciering – Wwft), whereby banks are expected to apply a risk-based approach in preventing and combating money laundering. Particularly in higher-risk situations, DNB expects banks to do more to prevent misuse of their services.

  • DNB investigated how ABN AMRO implements ongoing monitoring of customers and transactions, with particular attention to customers with increased integrity risks. This investigation shows that ABN AMRO failed to carry out adequate customer due diligence, as the ongoing monitoring was insufficiently critical, thorough and decisive. The fining decision explains DNB’s findings by reference to five customer files.

  • Given the nature, seriousness and extent of the shortcomings, DNB considers the imposition of an administrative fine necessary and appropriate. DNB has therefore imposed an administrative fine.

  • DNB and ABN AMRO have resolved this fining procedure through a simplified settlement. Following this simplified settlement, the fine has been set at €8.5 million.

Gatekeeper role

Tackling money laundering is a priority for the government because it is key to effectively fighting all manner of serious crime. Concealing the origin of criminal proceeds enables perpetrators to steer clear of the investigative authorities and enjoy their ill-gotten gains undisturbed. The Wwft aims to ensure that our financial system is not abused for money laundering and terrorist financing. Under this legislation, banks act as gatekeepers and are obliged to carry out anti-money laundering controls. This means that banks must know who their customers are, where the customers’ money comes from and what customers intend to do with financial products, e.g. payment accounts. Banks run the risk of giving malicious parties access to its financial products. Once customers are through the gate, the bank must monitor them on an ongoing basis and report unusual transactions to the Financial Intelligence Unit (FIU-NL) so that the investigative authorities can examine suspicious transactions. Banks must apply a risk-based approach, meaning that customers with a higher risk require more extensive due diligence than those with a lower risk.

Non-compliance

DNB investigated how ABN AMRO conducts customer due diligence on customers with increased integrity risks. In the five customer files discussed in the fining decision, concrete risk indicators were identified, such as large cash withdrawals by private individuals, transactions involving high- or increased-risk countries, large and frequent commission payments, potential involvement in dual-use goods, and signals that could indicate circumvention of sanctions against Russia by ABN AMRO customers, including through the use of intermediaries. ABN AMRO failed to investigate these signals with sufficient depth and did not act decisively enough to adequately mitigate the associated risks. In such cases, a risk-based approach requires enhanced and critical scrutiny. ABN AMRO relied to a significant extent on customer explanations without adequately verifying them against objective and verifiable information. Even where essential information was missing or customers failed to fully comply with information requests, investigations were often closed despite the higher risks, without appropriate follow-up inquiries or adequate measures. In addition, ABN AMRO did not consistently identify and assess relevant risk indicators in conjunction with one another.

These findings indicate a structural lack of depth in customer due diligence, which DNB considers serious.

DNB’s enforcement approach is aimed at ensuring compliance with the Wwft, whereby banks are expected to apply a risk-based approach in preventing and combating money laundering. Particularly in higher-risk situations, DNB expects banks to do more to prevent misuse of their services. Given the nature, seriousness and extent of the shortcomings, DNB considers the imposition of an administrative fine necessary and appropriate.

Amount of the fine

The fine imposed for the violation committed by ABN AMRO has been set at €8.5 million, in accordance with DNB’s General Fine Policy. In determining the amount of the fine, DNB took into account that ABN AMRO is a large undertaking with substantial financial capacity. In DNB’s view, the violation is serious and culpable. At the same time, DNB has taken into account the measures initiated by ABN AMRO to address the shortcomings. DNB has also weighed positively ABN AMRO’s constructive and cooperative attitude in its remediation efforts.

Fine with simplified settlement

DNB and ABN AMRO have resolved this fining procedure through a simplified settlement, in accordance with the AFM and DNB policy rule on simplified settlement of fines. This means that ABN AMRO acknowledges the facts underlying the established violation and accepts the fine. Consequently, ABN AMRO will not lodge an objection against the fine. In return, DNB reduced the fine from €10 million by 15% to €8.5 million and issued an abbreviated fining decision.

Read the full decision below (in Dutch), excluding confidential information. For more information, media representatives can contact Dorinde Meuzelaar: d.c.meuzelaar@dnb.nl or +31651963073.

Fine Wwft ABN AMRO (Dutch only)

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Download Fine Wwft ABN AMRO (Dutch only)

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