Title: Dutch Banks Unite Against Money Laundering with Transaction Monitoring Netherlands (TMNL)
Why TMNL? - The Importance of Collective Efforts
The Netherlands, like many other countries, loses an estimated €16 billion annually to money laundering, with only 2% of the illicit funds seized by authorities. To combat this pervasive issue, five Dutch banks – ABN AMRO, ING, Rabobank, Triodos Bank, and de Volksbank – have formed a non-profit collaboration called Transaction Monitoring Netherlands (TMNL).
The goal is to improve money laundering detection by identifying meaningful connections in banking data through intensified collaboration. Banks, under the current Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), play a crucial role in financial crime prevention. TMNL operates under five core pillars.
- Collaboration
- Legislation
- Privacy
- Secure data
- Responsible use of models
Collaboration
The alliance’s success lies in partnerships and collaborations. TMNL builds on existing relationships with key stakeholders like the Financial Intelligence Unit (FIU) and the Anti-Money Laundering Centre (AMLC). By pooling resources and focusing efforts, they aim to detect money laundering more effectively for Dutch society.
Legislation
TMNL seeks to strengthen the gatekeeper role of banks under the Wwft by fulfilling their legal obligations more effectively. In 2020, TMNL initiated activities within the legislative framework, but legal adjustments are required for its future development. The Dutch government has initiated the legislative process as part of the Anti-Money Laundering Action Plan.
Privacy
TMNL respects the importance of individuals’ privacy while performing its duties. It only uses essential data for monitoring potentially suspicious transactions and applies pseudonymization to sensitive information to maintain customer confidentiality. Data handling conforms to the General Data Protection Regulation (GDPR). TMNL currently focuses on business clients’ transactions.
Secure Data
Banks securely share transaction and client data with TMNL alone, ensuring data privacy. Robust IT security measures safeguard the data, protected by independent oversight. Encryption, access control, and pseudonymization maintain the security of sensitive data. Only authorized personnel can access this information.
Responsible use of Models
When analyzing potentially unusual transactions, TMNL employs models judiciously to ensure fair dealing and reduce discrimination risks. An oversight committee, comprised of external experts and representatives from the participating banks, supervises the use of these models.
The Future of TMNL
TMNL aims to expand its role in the broader financial crime prevention landscape by serving additional institutions in the future. Its collaborative approach to money laundering detection within the Netherlands and potentially the EU serves as a positive example of collective action against financial crime.