On Tuesday, April 12, 2016, the ACAMS Netherlands Chapter together with KPMG hosted a hot topic seminar on “Transaction Monitoring.” This topic greatly resonates in the Netherlands due to recent terrorist threats in Europe and worldwide. The Dutch Central Bank (DNB) is planning to conduct thorough thematic examinations in order to fine-tune guidelines on transaction monitoring and to strengthen their supervision in this area.
About 70 professionals were present, showing great demand of the seminar. Our members were significantly interested by the presentation of Maarten Ligthart, senior supervisor from the Expert Centre Integrity of the DNB, and other high-level professionals that are consulting and dealing with transaction monitoring issues on a daily basis.
The ACAMS Netherlands Chapter is grateful to KPMG, the speakers and participants for a highly informative afternoon, practical presentations and an interesting Q&A session. Below are the main insights/issues discussed.
According to Ligthart, the DNB decided to perform thematic research because previous examination revealed that financial institutions conducted insufficient run-based checks on customer transactions. Such deficiency led to a number of money laundering cases and even terrorist financing issues that were detected within a few financial institutions.
The DNB will conduct a deep dive on transaction monitoring with an emphasis on the following work streams:
- Test of design and effectiveness of the transaction monitoring processes
- Independent testing of the transaction monitoring system
The execution of the examinations is planned to be conducted on the second and third quarter of 2016. The best practices paper and general communication on the results of this thematic examination is planned for the end of this year.
Patrick Özer and Renske van Hooff, KPMG senior professionals, shared their experience in working closely with different institutions by providing them with advice on the organization of transaction monitoring processes. Following the results of their extensive experience they have concluded that the main issues that institutions are currently struggling with are:
- Data quality and its complexity
- Extensive data flows
- AML knowledge and employee training, including knowledge of tooling for transaction monitoring
Jeroen Buunen from DVB Partners mainly focused on the practical challenges and issues that occur between financial institutions and vendors providing software solutions for transaction monitoring processes. One of the main challenges that frequently takes place is financial institution’s and vendor’s ability to cooperate with each other with regards to sharing compliance and technological knowledge in order to create a solution that would be best applicable for a particular institution. Such cooperation shall be aimed to focus on the particular customer types of the institution, their transactions and other needs and at the same time exclude the false positive alerts at a maximum level.
The ACAMS Netherlands Chapter has already made plans for future events for the rest of 2016. Our main focus will be on topics such as the UBO register in the Netherlands, new anti-money laundering legislation, changes in the law regulating the activities of the trust offices and updates on sanctions. Final topics to be announced.