Fine for Travelex for failing to report unusual transactions in time
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De Nederlandsche Bank (DNB) imposed an administrative fine of €100,000 on Travelex N.V. (Travelex; formerly: Grenswisselkantoor – GWK) on 2 February 2023. This is because Travelex was late in reporting unusual transactions to the Financial Intelligence Unit (FIU-NL) for more than three years, even though the law requires prompt reporting of such transactions.
Late reporting of unusual transactions
Under the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme – Wwft), financial institutions (including Travelex) are required to report unusual transactions to the FIU-NL promptly, so that the FIU-NL can investigate the transactions and take action as needed. If an institution reports an unusual transaction late, the FIU-NL cannot immediately launch an investigation. This can contribute to (facilitating) money laundering and terrorist financing.
The Wwft provides that transactions with a value of €2,000 or more must always be promptly reported to the FIU-NL. Travelex failed to report several unusual transactions with a value of €2,000 or more promptly to the FIU-NL between January 2019 and February 2022. This means that Travelex acted in non-compliance with the Wwft.
Travelex noticed its non-compliance and reported it to DNB as an incident. Travelex has also since reported the unusual transactions to the FIU-NL.
DNB imposed on 2 February 2023 an administrative fine of €100,000 on Travelex for this non-compliance.
Objection
Interested parties have until six weeks after the decision has been made public to object to the fining decision.
Read the full decision below (in Dutch), excluding confidential information. For more information, please contact DNB's Information Desk on 0800 020 1068 (freephone in the Netherlands) or +31 20 524 91 11 if you call from abroad.
Boete voor Travelex vanwege het te laat melden van ongebruikelijke transacties (only in Dutch)