Study on money laundering and financing of terrorism

Date 26 February 2013
DNB is launching study on integrity risks at the branches of foreign banks.

DNB’s supervision on the Dutch branches of foreign banks focuses mainly on liquidity and compliance with two laws: the Money Laundering and Financing of Terrorism Act and the Sanctions Act. As announced in the theme brochure for 2013, this year DNB will be launching a cross-sectoral theme-based study on integrity risks. For the banking sector, this will focus primarily on the Dutch branches of foreign banks. 
Compliance with the Money Laundering and Financing of Terrorism Act
DNB expects from foreign banks with a Dutch branch to have conducted adequate risk analyses of their clients and products. It also expects them to have sound processes in place for monitoring transactions. To establish whether this is the case, DNB will study a group of selected banks in 2013. Its aim is to encourage the Dutch branches to do their utmost to ensure that they do not become involved in money laundering and the financing of terrorism. 
Sanctions lists
The Sanctions Act is designed to combat the financing of terrorism and prevent undesirable trade with countries that are included in international sanctions lists, such as Iran and North Korea. In recent years, various national supervisory authorities have imposed hefty fines on international banks that infringed this law. The investigations conducted by these authorities clearly showed that some banks were deliberately flouting the law, for example by engaging in transactions with blacklisted countries through neighbouring states. Partly for this reason, when studying the branches DNB will closely scrutinise the quality of their regular checks on customers and transactions concluded in the context of the Money Laundering and Financing of Terrorism Act and the Sanctions Act. 
DNB expects financial institutions to be aware at all levels of the need for and benefit of regulatory compliance. They must be sufficiently aware of the risks they are running, be able to quickly identify them and take appropriate action where necessary to fill gaps and minimise risks.
The study will start very soon. The banks taking part will be sent feedback on the individual findings relating to them by the middle of this year. DNB will then publicise the aggregate results for the banking sector as a whole through this newsletter and other channels.
If you would like to know more about this study, email supervisor Maarten Ligthart of the DNB expertise centre on culture, organisation and integrity at

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