On 6 July 2026, De Nederlandsche Bank (DNB), the Dutch central bank, imposed an administrative fine of €8.5 million on ABN AMRO for structural shortcomings in the ongoing customer due diligence of part of its high-risk customer base. The case is a timely illustration of what supervisors now expect from "ongoing monitoring" — and that bar is higher than many organisations think.
What happened
DNB examined the period from September 2023 to September 2024 and found that, in five customer files, ABN AMRO had not investigated concrete risk signals in sufficient depth. These included large cash withdrawals by private individuals, transactions with links to high-risk or elevated-risk countries, substantial and frequent commission payments, and signs that customers might be trying to circumvent the sanctions against Russia through intermediaries — including possible involvement of dual-use goods.
According to DNB, the bank relied too heavily on customers' own explanations without sufficiently verifying them, and closed investigations without appropriate follow-up or adequate measures. This is notable because the same bank had already reached a €480 million settlement with the Dutch Public Prosecution Service in 2021 for similar shortcomings.
Why this goes beyond banks alone
It is tempting to read this as a banking issue. That is a misconception. The signals DNB cites — unusual cash flows, transactions with elevated-risk countries, possible sanctions circumvention through intermediaries — are exactly the kind of risks that can also arise with a trading company's own customers, suppliers and end users.
Moreover, banks become more critical of their own business relationships as supervision tightens. A company whose transactions resemble these signals — even if nothing is wrong — runs a real risk of tougher questions, delayed payments or even termination of the banking relationship.
What supervisors now expect in concrete terms
The case offers a number of lessons that apply more broadly than the financial sector:
- One-off acceptance is not enough — customer due diligence does not stop at onboarding; it must be kept up to date throughout the relationship.
- Signals call for verification, not assumptions — a counterparty's explanation is a starting point for investigation, not an end point.
- Risk indicators must be combined — individual signals (a cash withdrawal, an unusual payment) carry more weight when they occur together.
- Closing without follow-up is not a solution — closing a file without removing the underlying risks does not solve the problem.
Example from practice
A trading company works with an intermediary that resells goods to a customer in a country with an elevated sanctions risk. Payments run through a third party and the commission structure is unusually high. Each element can be explained on its own, but in combination they form exactly the pattern that DNB identified as an insufficiently investigated signal. A thorough assessment of the ownership structure and the final destination of the goods would have brought this risk to light at an early stage.
Frequently asked questions
Does this decision only apply to banks?
No. The decision concerns a bank's obligations under the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), but the underlying risk indicators — cash flows, elevated-risk countries, possible sanctions circumvention — are relevant to any organisation that does business internationally.
What does this mean for my own banking relationship?
Banks are tightening their own customer due diligence under pressure from supervisors. Companies with complex structures, intermediary trade or transactions to high-risk countries may notice this in the form of additional questions or longer lead times.
How do I prevent my organisation from triggering a similar signal?
By carrying out thorough due diligence on customers, intermediaries and final destinations yourself — before a transaction takes place — rather than only responding to questions from the bank afterwards.
TradeRisk supports companies with customer due diligence and ongoing customer research, including the assessment of signals such as those described above. Also read more about what Enhanced Due Diligence involves and how sanctions screening works.