Update FATF-warning lists November 2026
05 November 2026
News item supervision
FATF released an update of its ‘grey’ and ‘black’ lists.
Read more Update FATF-warning lists November 2026De Nederlandsche Bank (DNB) conducted a survey among five Dutch banks to explore how they apply the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme – Wwft) to customers with a low risk of money laundering. Banks acknowledge the importance of proportionality but report facing constraints in applying the concept. We see opportunities for more tailored solutions and collaboration throughout the chain.
Published: 12 January 2026
© GettyImages
In recent years, concerns have grown about unintended side effects of anti-money laundering efforts by banks, including unnecessary burdens on customers, restricted access to payment services, operational pressures and (indirect) discrimination. Especially in low-risk situations, it is not always clear whether banks’ efforts are proportionate. Complaints received by DNB and other indicators raise the question of whether current practices in such cases are proportionate to the actual money laundering risk.
We carried out an exploratory survey at five Dutch banks in 2025 on proportionate application of the Wwft to customers with a low risk of money laundering and terrorist financing. The survey was prompted by indications that some Wwft procedures are seen as excessive, particularly for low-risk customer groups.
The aim was to understand how banks are tailoring their Wwft procedures for customers with low-risk profiles. The survey follows up on our previously published report From recovery to balance, which highlights the importance of a risk-based approach.
Four specific customer groups were targeted in the survey: charities and religious organisations, homeowners’ associations, small SMEs/retail customers and politically exposed persons (PEPs).
The survey reveals that banks acknowledge the importance of proportionality and have already taken steps in this area. There is a clear willingness to better align procedures with customer risk profiles. At the same time, banks report facing constraints. This could lead banks to take measures that are more burdensome than necessary, placing disproportionate pressure on customers and causing inefficiencies in operations.
These constraints are closely related to the areas of tension inherent in a risk-based approach. A risk-based approach requires banks to exercise professional judgement about risks and to take appropriate measures. Exercising professional judgement may involve asking customers probing questions or assigning them a higher risk rating as a precaution, even when their risk profile is acceptable. This conflicts with the principle of proportionality.
In addition, sound risk assessment requires sufficient customer information to build a complete picture and comply with the Wwft. However, the pursuit of completeness can lead to administrative burdens and frequent customer queries, which may clash with customer-centric service and efficiency, especially when banks request more information than needed to compile a risk profile, perhaps even overstepping legal requirements.
Banks classify their customers into risk categories, typically: low, medium and high. This classification determines the measures a bank applies when initiating and maintaining a customer relationship. The survey of the four customer groups reveals that customers in the homeowners’ associations and small SME/retail groups are predominantly classified as low risk. In contrast, greater variation is observed in the risk ratings for charities and, in particular, politically exposed persons (PEPs). Where customers are not classified as high-risk, additional burden does not stem solely from the risk rating. Other factors, such as internal procedures, interpretation of risk indicators, oversight procedures and differences in customer files, also play a role.
© DNB
Below, we reflect on our main observations for each customer group.
For this customer group, banks typically adopt a risk-based approach, classifying many organisations as low or medium-risk. This enables proportionate customer due diligence, allowing for less frequent reviews and a tailored approach in the case of complex ownership structures, such as religious institutions.
Where banks deploy specialised teams and apply customised processes, the survey shows that this results in a more proportionate application of the Wwft. Not only do these working methods reduces burdens, they also increases CDD efficiency and effectiveness
Case studies show that banks develop internal guidelines to differentiate within the non-profit sector, deploy specialised teams and use tools such as dedicated response forms to simplify customer interaction.
In practice, the use of cash (e.g. in collections), remittances to countries with risks of sanctions or terrorism, and board changes creating ambiguity around identifying UBOs are key concerns in the proportionate application of the Wwft. In such cases, it is up to the bank to make a proper assessment of whether these factors warrant additional measures. Real estate ownership also plays a role, which can lead to areas of tension in practice.
Should a foundation or church that owns real estate be classified as a business relationship involving commercial property? Often, the property is also rented out. According to internal bank procedures, it should. However, this classification significantly increases the amount of information the bank requires. The bank asks itself whether it is proportionate to label the foundation’s activities as commercial real estate activities, with the associated intensive disclosure requirements.
Homeowners' associations are predominantly classified as low-risk by banks because of their transparent legal structure, limited financial size and clearly defined purpose, which translates into less frequent reviews and a lighter approach to customer due diligence.
To further reduce administrative burdens, banks prefer pragmatic approaches. Yet bottlenecks remain. These associations are not legally required to register UBOs, yet the Wwft obliges banks to identify them. Board changes, shared ownership and external management complicate this process. In addition, customers may not understand why UBO information is needed in case of a low-risk profile. Volunteer board members often lack awareness of their legal obligations, which can increase customer interaction and create additional administrative burdens. Case studies show that using dedicated UBO forms and consolidating information requests contribute to more proportionate working processes and more efficient customer interaction.
When a bank requires information from multiple homeowners’ associations managed by the same administrator, it consolidates the requests into a single query. This allows the administrator to provide information for all associations at once, reducing duplication, easing communication and improving efficiency.
Customers in this group typically do not exhibit many characteristics associated with elevated money laundering risk. Although banks generally do not have dedicated policies for this group, they increasingly recognised it as posing a low risk. This allows for a less burdensome application of customer due diligence, such as less frequent reviews and using existing information,
In practice, automated CDD assessments are also used where annual turnover remains below a set threshold and no other risk factors are present. In cases involving transactions with high-value goods, a value threshold is applied to determine whether additional due diligence is necessary.
One major concern is the use of cash, most notably in the hospitality and retail sectors. While this may be seen as a potential risk indicator, it often aligns with expected transaction profile in these sectors. Asking probing questions about the origin of cash in such cases may be disproportionate and could strain the customer relationship, also leading to inefficient use of resources.
An analyst notices cash flows in a customer’s account – a restaurant. Aware that cash transactions can be a relevant indicator of increased money laundering risk, the analyst assigns a higher risk rating, even though there is no concrete evidence of elevated risk other that the use of cash. This decision leads to additional inquiries. In doing so, the analyst overlooks the fact that cash flows are relatively common in the hospitality sector – a factor that could have supported a different, more proportionate assessment.
The Wwft requires banks to apply additional customer due diligence (CDD) measures when dealing with Politically Exposed Persons (PEPs). Banks often classify PEPs as high risk by default, but this is not always necessary. The survey shows that banks that have adopted the NVB Industry Baseline on PEPs tend to differentiate more carefully, resulting in a smaller proportion of PEPs being classified as high risk. Wider implementation across the sector could lead to less intensive measures and allow for less frequent reviews and more proportionate assessments regarding the origin of a PEP’s assets.
Case studies show that banks consider the presence of risk factors to determine whether a reassessment is needed. For instance, if a customer is a relative of a PEP and there have been no changes in circumstances, no further inquiries will be made. This improves resource allocation and reduces the burden on customers.
A bank considers whether the origin of a PEP’s assets should be reassessed based on the presence of specific risk factors. The bank takes into account the type of PEP involved and relevant circumstances. For example, if an existing customer is a close relative of a PEP and must be classified as a PEP under the Wwft, the bank assesses whether there are indications that this relative poses an increased risk. If there are no signs of changed circumstances or other relevant risk indicators, this is documented and no further inquiries are made. This approach allows the bank to allocate its resources more effectively and reduces the burden on customers.
Bottlenecks include the fact that some banks still classify PEPs as high risk by default, leading to unnecessarily intensive CDD measures. Areas of tension with regard to proportionality arise, for example, when requesting statements of assets from PEPs who present low money laundering risks or hold a management position with low-risk customers.
We conclude on the basis of our survey that more proportionate application of Wwft requirements is achievable. Key factors include strengthening institutional expertise, centralising access to relevant information, applying standards carefully and encouraging professional judgement. What matters is using the scope to apply risk-oriented judgement rather than rigidly following procedures and avoiding mistakes. The goal is not to eliminate all risk, but to take measures that are proportionate to the risk.
Important preconditions are the boldness and purpose which employees need if they are to act with confidence and authority, adopting tailored solutions that may not be in accordance with standard procedures. It also means accepting that working proportionately means some risks may be overlooked or misjudged. Another crucial precondition is staff guidance that puts the purpose of the Wwft centre stage – managing risks related to money laundering and terrorist financing.
This is why we stress the importance of professional training, reflection and sharing best practices in the sector. Also, banks always have the option of not applying standards and risk indicators automatically, interpreting them in the context of the broader customer profile and actual risk.
As a supervisory authority, we advocate an approach that allows for tailored solutions and responsible acceptance of residual risks. This is also important in the management of high risks, and allows for a sharper focus on precisely these risks.
05 November 2026
News item supervision
FATF released an update of its ‘grey’ and ‘black’ lists.
Read more Update FATF-warning lists November 2026
05 November 2026
26 October 2026
News item supervision
As of 23 October 2026, all application forms for fit and proper assessments will require applicants to provide invoice details for the assessment fee.
Read more Request for invoicing details for fit and proper assessments
26 October 2026
15 October 2026
News item supervision
The revised market risk capital requirements under the Fundamental Review of the Trading Book (FRTB) will become applicable on 1 January 2027. The European Commission (EC) and the European Banking Authority (EBA) have published further clarification on this matter.
Read more DNB calls on institutions to prepare in a timely manner for the introduction of FRTB on 1 January 2027
15 October 2026
12 October 2026
News item supervision
De Nederlandsche Bank (DNB) will organize a physical information session about fit and proper assessments on Thursday 5th November from 3:00-4:45 PM CET. Please note that this session will only be held in Dutch, you are of course welcome to ask your questions in English.
Read more Information session about fit and proper assessments DNB (November 2026)
12 October 2026
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