Executive summary
Money laundering is a major social problem. Every laundered euro is the proceed of a criminal activity. Selling a building purchased with the proceeds of drugs trafficking or other crime gives the money the semblance of legitimacy. Estimates put the amount of money laundered in the Netherlands at between €15 billion and €20 billion. Bank accounts are key to money laundering.
Banks in the Netherlands are required by law to carry out due diligence to identify and reject criminal customers, prevent money laundering, and report unusual transactions. A study by De Nederlandsche Bank (DNB), the national supervisor, found that many banks do not comply with anti-money laundering regulations. Several substantial settlements by banks with the Public Prosecution Service in 2018 and 2021 and firm action by DNB obliged banks to comply with the anti-money laundering regulations at great expense. According to DNB some banks are still not meeting the statutory requirements.
The number of unusual transactions reported by banks since then has risen from nearly 250,000 to more than 530,000 in 2024. At the same time, there are indications that citizens and businesses are facing unnecessarily rigorous anti-money laundering checks and even discrimination.
Money laundering has to be tackled effectively and efficiently. It has to be prevented without citizens and businesses being disadvantaged by an approach that misses its target. Effective and efficient money laundering has to be risk based: due diligence checks and control measures must reflect the actual risk of money laundering and the amount involved. The Netherlands Court of Audit has found that the current approach is inadequately effective and is not risk based.
Anti-money laundering checks have serious consequences but the results are unknown
Our audit reveals that the anti-money laundering approach has serious consequences for certain groups of citizens and businesses. We examined 3 groups of banking customers: politically exposed persons (PEPs), religious institutions and hospitality businesses. Religious institutions and PEPs in particular are inconvenienced by the checks. There are significant differences both between and within these groups. Migrant churches and mosques face far more inconvenience than catholic and protestant churches. Islamic organisations have been informing the Minister of Finance since April 2022 of possible discrimination by banks. Our audit, too, revealed signs of discrimination. Unlike religious institutions and PEPs, most hospitality businesses said they were not unduly inconvenienced.
Anti-money laundering policy is designed to prevent or detect laundering. However, the policy results are largely unknown. It appears hard to substantiate that money laundering is actually being prevented. Failings in the quality of the banks’ unusual transaction reports, moreover, frustrate the investigation of money laundering. It is not known how many transactions have been reported concerning the groups we audited and how many actually involved money laundering.
We were unable to establish that the ministers concerned considered the results of anti-money laundering policy. Society is paying a high price for the policy. The cost to banks alone is high: the banks we investigated deployed some 13,000 FTEs to combat money laundering in 2024.
Role of the organisations concerned
We investigated the role of 4 public organisations in the anti-money laundering chain:
- DNB supervises compliance with anti-money laundering measures. DNB requires non-compliant banks to undergo lengthy restorative programmes and take remedial measures to rectify compliance shortcomings by a set date. In practice, this has led to banks conducting rigorous due diligence checks that are not risk based. DNB does not assess the effectiveness of its supervision. It announced in 2022 that anti-money laundering checks should be risk based. Our audit of the period 2019-2024 found little of this change of course.
- Banks must report unusual transactions to Financial Intelligence Unit–The Netherlands (FIU-NL). Partly on account of the remedial programmes, banks have been reporting far more transactions. The working method of FIU-NL has vulnerabilities. FIU-NL does not know, for instance, which reports it has dealt with. Furthermore, it does not assess the quality of the reports it receives.
- The Minister of Finance and the Minister of Justice and Security (J&V) presented plans in 2019, 2022 and 2025 to improve the anti-money laundering approach. Many of the goals set in 2019, such as a more risk-based approach, were still on the agenda in 2025. The Minister of Finance oversees DNB and the Minister of J&V oversees FIU-NL. In practice, the Minister of Finance oversees DNB at a distance, chiefly with regard to cost control rather than operational effectiveness and efficiency.
- Achieving results requires collaboration and a common understanding among all the parties involved. We found that the parties did not work well with each other and valuable information went unheeded.
Conclusions and recommendations
An effective and efficient approach to money laundering is risk based: the selection of checks and control measures should be based on the actual risk of money laundering and the amount involved.
Our main conclusion is that effectiveness and efficiency are currently open to improvement. There are many intrusive checks but little insight into their efficacy. Little is done to improve insight. In our opinion, this is a missed opportunity. The insight is necessary for a risk-based approach. As a result, the current approach is particularly rigorous for certain groups of citizens and businesses, but it is not known whether they actually present a higher risk. Our audit found signs of discrimination.
There are opportunities for all parties concerned to improve the anti-money laundering approach’s effectiveness and efficiency. We recommend that the Minister of Finance and the Minister of J&V:
- inform the House of Representatives before the end of the year of the concrete measures they will take to make the approach to money laundering more risk based. Such an intention was shared with the House as long ago as 2019. The new approach should improve insight into effectiveness and prevent discrimination.
An effective approach to money laundering stands or falls on the quality of unusual transaction reports. There are significant differences in the quality of the reports banks make to FIU-NL. In practice, DNB and FIU-NL do not assess the quality of the banks’ reports. We recommend that DNB and FIU-NL:
- pay more attention in their joint activities to the quality of reports made by banks;
- make better use of modern analytical techniques. Better data analysis would improve DNB’s insight into the approach’s impact on banks and their customers. FIU-NL could then give higher priority to the banks’ reports and improve its insight into laundering phenomena.
A look to the future: future European rules and SAI audits
Banks in the Netherlands are required to report with a lower threshold than banks in other European countries. New EU rules coming into force in 2027 will remove this anomaly. A new EU institution will be established in 2028 to supervise selected financial institutions.
In collaboration with supreme audit institutions in other EU member states, we will publish a report on this topic in a European context later this year. This parallel audit will look at problems the establishment of a new EU institution might cause for our audit of the anti-money laundering approach. It will also highlight differences and similarities in the anti-money laundering approach in the countries concerned.