Outdated browser

You are using an outdated browser. DNB.nl works best with:

Guidance for the transaction monitoring process at money transfer organisations (MTOs)


Our guidance document (see the related downloads section) lists the main findings from our 2016 thematic examination "Post-event transaction monitoring at banks"1. Our findings show that payment institutions do not yet sufficiently control their transaction monitoring process with respect to money laundering and terrorist financing risks. This document shows you how to improve your transaction monitoring process. When developing solutions and measures you should of course take into account your institution's own circumstances. You have to make your own considerations in this respect.

Published: 24 November 2022

Explanatory notes to the guidance document

The structure of the guidance document is as follows. After an introduction and a brief description of the transaction monitoring process, we present the maturity model we used in our 2016 thematic examination. For each element of the model, we explain the main findings from the examination and present the do's and don'ts resulting from our thematic examination for each component of the maturity model.


At the end of May 2017, DNB organised round table sessions on the draft guidance document. We integrated the feedback obtained from these sessions, as well as the written response provided by the partaking institutions, into this final version of our guidance document.

[1] A cross-sectoral examination was performed at four banks, four payment institutions, three money transfer offices, and six trust offices.