Follow-up survey into banks’ approach to preventing discrimination

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De Nederlandsche Bank (DNB) has concluded its 2025 follow-up survey into how banks and payment service providers prevent discrimination in their compliance with the Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft). 

Published: 29 September 2025

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The findings are set out in the report Counteracting Discrimination – Actively Addressing the Risk.

This year's survey not only revisits banks’ practices as examined in 2024, but also looks at discrimination in their compliance with the Sanctions Act 1977 (Sw). For the first time, payment service providers were included in the scope.

Banks

The survey shows that banks have taken important steps to strengthen their approach to preventing discrimination, demonstrating progress since the previous survey. At the same time, DNB finds that there is still room for improvement, particularly in addressing indirect discrimination. To support further progress, DNB includes guiding recommendations for banks in its report.

Payment service providers

Payment service providers also show positive developments, but similar opportunities for improvement exist. DNB also includes guiding recommendations for payment service providers aimed at reinforcing their anti-discrimination measures.

Follow-up

Participating banks and payment service providers will receive individual feedback on the results. DNB will continue its supervisory dialogue with institutions, focusing on unintended side effects of compliance with the Wwft and sanctions legislation.

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