What happened? Dutch online bank Bunq has been fined €2.6 million by the Dutch Central Bank (DNB) for failures in its anti-money laundering (AML) controls. The regulator cited serious shortcomings between January 2021 and May 2022, where Bunq failed to properly investigate and report potential financial crime indicators. [NB Bunq passports its credit institutions services into Ireland from the The Netherlands pursuant to the terms of the EU Directive 2013/36/EU]. DNB noted that Bunq had previously been warned and fined for similar weaknesses, yet meaningful improvements were not made. Despite this, Bunq maintains that it takes its gatekeeping responsibilities seriously, pointing to its use of advanced technology and ongoing system improvements. This fine comes against a backdrop of heightened regulatory scrutiny in the Netherlands, where major lenders including ING, ABN Amro, and Rabobank have also faced significant enforcement actions and legal challenges over AML control deficiencies. banks must know who their customers are, where the customers’ money comes from and what customers intend to do with financial products, e.g. payment accounts. - De Nederlandsche Bank 25 August 2025 What is important for MLROs to note from this case This case underlines the importance of sustained, demonstrable improvements in AML frameworks, particularly following regulatory warnings or fines. For an MLRO, the key lesson is that technology alone is insufficient without robust governance, oversight, and a culture of accountability. Regulators expect not only initial remediation but also evidence of lasting effectiveness in transaction monitoring, customer due diligence, and suspicious activity reporting. An experienced MLRO should recognize that repeated regulatory findings indicate weaknesses in escalation, board engagement, and risk ownership. Embedding AML into the bank’s strategic priorities—through continuous training, effective quality assurance, and proactive engagement with regulators—is essential. Failure to do so not only risks financial penalties but also reputational damage and possible criminal liability for the institution and senior management. Work conducted by the DNB DNB conducted an examination into the way in which Bunq complies with the Wwft. As part of the examination, DNB assessed how Bunq analyses and assesses its risks of facilitating money laundering and terrorist financing. In addition, it examined customer files and the transaction monitoring alerts associated with these files and conducted interviews with relevant officers. The high-risk files examined showed that Bunq was deficient in following up on its transaction monitoring alerts. As a result, signals of possible financial crime were not investigated in sufficient depth, if at all. Bunq was also unable to demonstrate why transactions with similar characteristics were reported to FIU-NL in one case and not in the other. As a result, there was a risk that unusual transactions were not detected, or not detected in time and that they were not reported, or not reported in time. Transaction monitoring deficiencies can cause illicit money flows to continue unchecked. Bunq failed to exercise adequate ongoing monitoring in the four files on which DNB's administrative fine is based. As a result, Bunq did not have sufficient insight into these customers and their transactions. Given the severity and extent of the deficiencies in these files, DNB considers the fine imposed both necessary and appropriate. What is the justification for the size of the fine? Between 2018 and 2023, DNB carried out several examinations into Bunq’s compliance with the Wwft. During these examinations various instances of non-compliance with the Wwft were identified, that were found to be both severe and culpable. DNB already took enforcement action on several occasions, including imposing a fine. However, this has not resulted in sustained compliance with the Wwft by Bunq. Following DNB’s examinations, Bunq has not made sufficient progress in complying with its statutory obligations under the Wwft. DNB has therefore decided to impose a punitive fine on Bunq due to the severity of the non-compliance with Section 3(2)(d) of the Wwft. DNB’s enforcement approach is primarily aimed at compliance with the law. In addition, the more severe and culpable the non-compliance, the sooner DNB will impose a fine. This is done on a case-by-case basis. Bunq's size and ability to pay have been taken into account, and the fact that Bunq completed a remedial programme to address the identified deficiencies after DNB's most recent examination has been taken into account in favour of the bank. Can Bunq appeal? Bunq lodged an objection to DNB's decision to impose a fine. The objection process is still pending. A decision becomes final if no legal remedy has been exercised against it. Any interested party may lodge an objection against the decision within six weeks of its date. The decision on the objection can be appealed in court within six weeks. Further appeal against the court ruling may be lodged with the Trade and Industry Appeals Tribunal (College van Beroep voor het bedrijfsleven – CBb). If no objection, appeal or further appeal is lodged, the decision becomes irrevocable. The table shows the current status of this decision. What is the gatekeeper role of the DNB? From the DNB's website: "Tackling money laundering is a priority for the government because it is key to effectively fighting all manner of serious crime. Concealing the origin of criminal proceeds enables perpetrators to steer clear of the investigative authorities and enjoy their ill-gotten gains undisturbed. The Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en terrorismefinanciering – Wwft) aims to ensure that our financial system is not abused for money laundering and terrorist financing. Under this legislation, banks act as gatekeepers and are obliged to carry out anti-money laundering controls. This means that banks must know who their customers are, where the customers’ money comes from and what customers intend to do with financial products, e.g. payment accounts. Once customers are accepted, the bank must monitor them on an ongoing basis and report unusual transactions to the Financial Intelligence Unit (FIU-NL) so that the investigative authorities can examine suspicious transactions. Banks may use a risk-based approach to monitor their customers, meaning that high-risk customers will require more in-depth monitoring than low-risk customers." Sources:
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