This more risk-based approach is intended to help keep the financial sector cleaner and improve the effectiveness of the fight against financial crime, while at the same time helping to ensure that overly stringent controls do not lead to the unnecessary denial of services to customers.
Financial institutions and other stakeholders have until November 30th to respond to the proposals. The final version of the policy document will be published in early 2024.
DNB’s proposals follow its call last year in its report “From Recovery to Balance” for a more risk-based approach to preventing financial crime. In the report, DNB states that current practice can be made more targeted while remaining within the legal framework of the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en terrorismefinanciering – Wwft).
Financial institutions can conduct their checks on customers and transactions more efficiently and effectively, partly by using innovative technology such as machine learning, and by emphasising a risk-based approach. In addition to being more targeted, the more risk-based approach should also help to ensure that stringent controls do not unnecessarily impede customers’ access to banking services and the financial system.
Following last year’s publication of From Recovery to Balance, financial institutions and DNB met in a series of round-table sessions to discuss the details of the new approach. Based partly on these discussions, the Dutch Banking Association (NVB) has published its own standards, including examples of how banks can implement specific Wwft provisions. DNB’s new policy document focuses on the entire financial sector.
See also Consultation DNB Wwft Q&As and Good Practices
See also the From recovery to Balance report, September 2022
For more information, please contact Tobias Oudejans by telephone at +31 (0)6 - 524 96 961.