National supervision of banks: European AMLA to be established in 2027

Banks are required by law to take measures to reject criminal customers and identify money laundering transactions. Banks that detect unusual transactions must report them to the Financial Intelligence Unit (FIU). In the Netherlands, DNB, the Dutch central bank, supervises all banks, payment institutions, pension funds, trust offices and other financial institutions.

For the first time since 1991, the EU has issued a money laundering directive, based on the international standards of the Financial Action Task Force (FATF). Its objective is to prevent the financial system in the EU being used to launder money or finance terrorism. The Netherlands has largely incorporated the directive in the Money Laundering and Terrorism Financing (Prevention) Act (WWFT). This act also provides for DNB’s integrity supervision of banks.

DNB is studying the banks’ compliance with the act and how they manage money laundering risks. The study is also considering the banks’ risk analyses and heir alignment with transaction monitoring systems, customer due diligence and whether and how banks report unusual transactions to FIU-NL.

The EU adopted laws in 2024 to combat money laundering and terrorism financing. Most parts of this legislative package will come into force as from 2027. One consequence will be the establishment in July 2027 of a new EU supervisor, the Anti-Money Laundering Authority (AMLA). It will assume supervision of selected institutions from DNB, which will have consequences for DNB’s activities.

Situation in the Netherlands and the Court of Audit’s audits

The Court of Audit has examined the Netherlands’ approach to money laundering and issued its report in March 2026. The report also considers DNB’s anti-money laundering supervision of banks.

The audit concluded that DNB’s supervision made only a limited demonstrable contribution to the prevention of money laundering. It also concluded that DNB’s integrity supervision was risk-based in theory but enjoyed limited application in practice. DNB’s supervision was directed chiefly at a number of banks that did not comply with the WWTF and were subject to remediation processes. The deadlines to complete remediation processes had been extended at least once. DNB does not evaluate why they are extended. Substantially and procedurally, we can largely follow the investigations and interventions that DNB carries out at banks in remedial processes.

DNB has contributed to a risk avoidance attitude among banks. The excessive checks they consequently carry out are not designed to prevent or detect money laundering. We also found that the Minister of Finance operates at some distance form DNB and accordingly has little insight into its performance. We came to a similar conclusion in 2017 regarding the minister’s oversight of DNB’s prudential supervision and in 2019 regarding DNB’s resolution activities.

In 2026, we will issue a joint publication on the anti-money laundering approach with several other European supreme audit institutions. We are collaborating with the audit institutions of Cyprus, Germany, Poland and Spain.The report will also consider possible negative effects of the arrival of AMLA. When AMLA assumes DNB’s tasks for selected banks in 2027, it will no longer be possible for us to access certain supervisory information that is necessary for the national audit on the anti-money laundering approach. If this is the case, there will be an audit gap in this area.

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