News · Enforcement
DNB Fines ABN AMRO €8.5M Over High-Risk Customer Due Diligence Failures
By Michael S · ComplyFocus
De Nederlandsche Bank (DNB) has imposed an €8.5 million administrative fine on ABN AMRO Bank N.V. over serious, structural shortcomings in its anti-money laundering controls for high-risk customers, the Dutch central bank said.
The penalty follows a DNB investigation covering the period from September 2023 to September 2024, during which the supervisor examined a selection of customer files and found recurring failures in the bank’s ongoing monitoring of clients posing increased integrity risks. In its decision, DNB illustrated the shortcomings by reference to five customer files.
What DNB found
According to the regulator, ABN AMRO repeatedly failed to investigate or act on concrete risk indicators. The signals it did not scrutinise sufficiently included:
- Large cash withdrawals by private individuals.
- Transactions involving high-risk or heightened-risk countries.
- Substantial and frequent commission payments.
- Signals that could indicate circumvention of sanctions against Russia.
DNB said the bank too readily accepted customer explanations without verifying them, closed investigations despite elevated risks without taking adequate measures, and did not consistently assess relevant risk factors together. The regulator described this as “a structural lack of depth in customer due diligence,” which it considers serious.
A reduced, settled fine
The fine was originally set at €10 million but reduced by 15% to €8.5 million under a “simplified settlement.” In accepting that settlement, ABN AMRO acknowledged the facts underlying the violation and agreed not to lodge an objection. DNB said it also weighed positively the bank’s cooperative attitude and remediation efforts.
ABN AMRO said it accepts DNB’s conclusions and the factual findings, and confirmed it has taken further remediation measures to strengthen the effectiveness of its AML processes.
Why it matters
The action is a reminder that regulators increasingly penalise weak execution of due diligence — not just missing policies. DNB’s findings centre on failures of enhanced due diligence and ongoing monitoring for high-risk customers, the very areas a risk-based approach is meant to strengthen. For compliance teams, the message is clear: identifying a red flag is not enough — it must be investigated and acted upon.
Under the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), banks are expected to apply a risk-based approach and to know who their customers are, where their money comes from, and what they intend to do with their accounts. Failures in that duty allow illicit funds to move through the financial system — the pattern described in the three stages of money laundering.
Source: De Nederlandsche Bank (DNB) enforcement notice, “Fine for ABN AMRO Bank N.V. for inadequate customer due diligence for high-risk customers,” dnb.nl.
