Questions about ABN AMRO and the AML investigation

What is ABN AMRO being accused of?

The bank is paying a fine to the DPPS for shortcomings in its anti-money laundering processes in the Netherlands in the period 2014-2020. The shortcomings relate to client acceptance processes, transaction monitoring and termination of relationships with certain clients. In certain cases, it was possible to abuse ABN AMRO’s accounts as a result of these shortcomings. The DPPS believes that ABN AMRO could have reasonably suspected that in certain cases clients were using their ABN AMRO accounts to launder money.

What happened?

Since 2014, ABN AMRO has taken various measures to remedy shortcomings identified within the bank’s different businesses. With hindsight, we have to conclude that our remediation programmes were insufficient to remedy all of the shortcomings. This deeply affects us. Wewere insufficiently successful in living up to society’s expectations of banks as gatekeepers of the financial system. That’s why we want to express our sincere apologies to our clients and society.

Why did the bank opt for a settlement?

Because we recognise that there were shortcomings. By accepting the settlement, we are publicly providing accountability for the shortcomings and we can turn our focus to the future.

ABN AMRO is paying the DPPS 480 million euros. Will this cost be passed on to clients?

The fine is being paid from the bank’s capital buffers – our reserves. At the same time, the requirements relating to our role of combating money laundering have increased in recent years, as have the costs of fulfilling this role. The bank already includes part of these execution costs into its rates.

The bank had already known for a few years that it did not have all of its affairs in order. What has ABN AMRO done since then?

In the past, we implemented several remediation programmes aimed at remedying shortcomings identified at different departments across the organisation. In 2018, we established that these programmes did not always lead to the desired structural solutions. So in October 2018, we decided to set up a central department, Detecting Financial Crime (DFC), to address this matter, and the department started operating in 2019. The DFC department aims to remedy the daily processes for assessing new and existing clients and to detect and combat criminal money flows. The remediation programmes are expected to run until the end of 2022 and have been coordinated with the Dutch central bank (DNB), and DNB is closely monitoring progress.   

Will ABN AMRO be more cautious in taking on new clients?

As a bank, it is our responsibility to know all our clients well – existing clients and new clients. Only then can we make the right assessment to decide whether or not to do business with certain clients. The gatekeeper role requires us to strictly check who we have on our books as clients and who we accept as a client. In certain situations, this can lead to us rejecting a new client or terminating relationships with an existing client. We are not necessarily more cautious, but we are diligent in taking on new clients and assessing existing clients.

Will the client’s identity need to be reconfirmed?

No, the settlement is not requiring the bank to reconfirm the identities of its clients. Of course, the bank needs to be well informed as to who its clients are and must keep proper records for this purpose. It may occur that as part of a regular process, a client is asked toreconfirm his/her identity. In all such instances, we will announce that in advance and explain how we will be doing this. We never ask clients to give their PIN codes, transfer money or report their security codes for online banking.

Can banks be held responsible for preventing money laundering from happening?

Putting an end to financial crime cannot be achieved by banks alone. But it starts with us, because banks have insight into their clients’ money flows, and they have an important role as gatekeepers in combating money laundering. Banks also have a duty to report unusual money flows. In addition, public parties such as the Dutch Fiscal Information and Investigation Service (FIOD), the DPPS and the police have information that we do not have. By joining forces, we can combat money laundering more effectively and work together to create a sound financial system and a safer society.