Detecting Financial Crime

“Financial crime is becoming increasingly sophisticated and organised. Criminals use the latest technology to get their money into the global financial infrastructure. The constructions they devise to do this are getting more and more creative. That’s why it’s increasingly important we stay a step ahead of them in order to reduce the risks to society, the financial system, the bank and our clients.

We’re entering a new chapter and there are still huge gains to be made when it comes to detecting and preventing financial crime. We must be able to respond rapidly to the criminal world around us. And we can only do that when we stand united with clients, other banks and the government against this form of criminality.”

“As a bank, we play an important role in safeguarding the global financial system. Every day at DFC we’re striving to prevent financial crime, of which money laundering and the financing of terrorism are perhaps the best-known forms. It’s a gatekeeper role that we take very seriously, both our responsibility to society but also our legal obligations to prevent money laundering and financing terrorism.

We aim to be a bank our clients can rely on, now and in the future. Because we’re well aware of the negative impact of financial crime; that it damages individuals and companies, and in extreme cases can even undermine entire economies.”

“Stopping criminal money from entering the financial system is all about knowing your clients well: who are they, what they do, where their money comes from and where it goes?

When someone applies to open an account with us, we probe further now into why they want to bank with us and what they’ll be using their account for. This lets us make a good risk estimate. Or we may require missing or additional information from a client for monitoring purposes or our periodic review.

Once in a while, we update the data on each client, for example checking whether their business activities still correspond with the activities listed in their documentation and transactions on their account. This is a necessary part of the relationship we have with every client: we have to fight this battle together.”

“It remains a game of cat-and-mouse. Certainly in today’s world, where technological developments are happening at breakneck speed. So we must ensure we limit the criminal’s options as much as we can, so they have nowhere to go with their illegal money.

We can stay ahead of them by joining forces. For example, in 2020 we were one of five banks to set up Transaction Monitoring Netherlands. By working together in the area of transaction monitoring, we’ll in future be able to detect the tracks left by criminal money better and earlier, strengthening our role as gatekeepers of the financial system. Before, a criminal could launder a small amount of money at each bank, without us knowing this was happening. Our continuous joint monitoring means this is happening less and less.”

“We’re not able to do this on our own. It's our duty to ask the right questions and the client’s duty to provide the right answers: it’s reciprocal. Moreover, a client may be unaware that their account is being used to move criminal money within the financial system. In which case, we investigate this together with them.

Obviously, we try to minimise the impact of DFC's work on our clients. For example, by having efficient processes and explaining clearly why we need their help. Because as I said, to fight financial crime effectively we will all have to pull together.”

• EUR 2 trillion are laundered annually worldwide.
• EUR 16 billion is laundered annually in the Netherlands.
• EUR 3 billion is the estimated amount of drugs money in the Netherlands, most of it cash.
• EUR 9 billion is earned through fraud.
• The Netherlands is #6 on the world’s list of most attractive countries for money laundering.
• Over 700,000 Unusual Transaction Reports were reported to the Dutch Financial Intelligence Unit (FIU) in 2020. Of these, around 104,000 transactions, with a total value of more than EUR 15 billion, were designated suspicious.

• The transaction doesn’t match the client's profile.
• The origin or destination of the money is unclear or unknown.
• The transaction was executed with a (foreign) counterparty who is insufficiently verifiable.
• The transaction was executed with a counterparty over whom there have been negative reports in the media.
• The client's statement about the transaction is unclear and cannot be sufficiently substantiated by documentation.

Since 1 January 2019, Robin de Jongh has been responsible for Detecting Financial Crime (DFC), a department of over 2,700 colleagues who manage financial crime risks for ABN AMRO.

“If we do our job well, everyone benefits: we know our clients better, they feel comfortable with an honest bank and we live up to society’s expectations. That for me is a perfect mix. I’ve also discovered that detecting financial crime is a far-reaching and complex field, so I learn a lot from my work. Collaborating with government and other banks, and innovating in the area of integrity risk management, for example through AI, are just some of the fascinating aspects of this work. "