The Dutch Central Bank (DNB) fined ABN AMRO €8.5 million after identifying weaknesses in the bank’s ongoing monitoring of certain high-risk customers. The regulator highlighted shortcomings in the effectiveness of customer reviews and the ability to identify changing risk profiles.
Lessons Learned
- Customer risk assessment cannot stop at onboarding; it must evolve throughout the customer relationship.
- High-risk customers require enhanced monitoring supported by quality data and clear escalation processes.
- Regulators increasingly expect firms to demonstrate that controls are working, not simply that procedures exist.
Key takeaway: A strong CDD framework is a living process, not a one-time compliance exercise.