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18 October 2022 Supervision

Response to Tribunal ruling in bunq case

Entree DNB Toorop gebouw

We have taken note of the ruling of the Trade and Industry Appeals Tribunal (CBb) in the bunq appeal case. We note that the Tribunal found that we have proved that bunq is in non-compliance with various provisions of anti-money laundering rules. Specifically, the Tribunal referred to the obligation to investigate the source of a customer's financial resources and the obligation to establish the identity of the ultimate beneficial owner, along with non-compliance with the rules governing enhanced customer due diligence in the case of politically exposed persons.

The Tribunal ruled there was insufficient substantiation for a number of the instances of non-compliance which we had found. We will assess the ruling and explore its implications for our supervision. We will also take the ruling onboard in our dialogue with the financial sector on risk-based compliance with statutory requirements and the use of technology to combat money laundering.

Sector(s)

  • Banks