Financial Crime World

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Dutch Banks Join Forces to Combat Financial Crimes, Lure €16 Billion in Annual Laundering

The Netherlands has long been plagued by financial crimes, with an estimated €16 billion laundered annually. Only two percent of these funds are actually confiscated, leaving room for improvement.

Transaction Monitoring Netherlands (TMNL)

To combat this issue, five major Dutch banks - ABN AMRO, ING, Rabobank, Triodos Bank, and Volksbank - have founded Transaction Monitoring Netherlands (TMNL). This collaboration brings together transaction data from the participating banks to identify meaningful connections between them, providing new insights into potential money laundering and terrorist financing.

Benefits of TMNL

  • Enables banks to detect potentially unusual patterns more effectively
  • Reveals hidden connections that might otherwise go unnoticed
  • Allows investigative services to tackle financial crimes with greater efficiency
  • Makes better use of public funds and limits the space for criminals to operate

Background

Under the current Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), banks play a crucial role in preventing financial crimes. Until recently, each bank worked individually to identify unusual transactions and report them to the Financial Intelligence Unit - Netherlands (FIU). However, money laundering networks often span multiple banks, making individual efforts insufficient.

TMNL’s Core Pillars

  • Collaboration: Relies on the participation of individual banks to detect unusual transaction patterns
  • Legislation: Seeks to fulfill its role as a gatekeeper under the Wwft and provides some framework for amendment
  • Privacy: Only uses essential data for monitoring potentially unusual transactions, applies pseudonymization of sensitive personal data, and processes personal data in accordance with the General Data Protection Regulation (GDPR)
  • Secure Data: Ensures strict IT security measures, including pseudonymization, data encryption, and access control
  • Responsible Use of Models: Eliminates any risk of discrimination through a special committee of external experts and representatives from participating banks

Future Plans

TMNL aims to expand its services to include other institutions beyond its founding banks. This would increase its contribution to overall financial crime prevention and serve as a model for the European Union and beyond.

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