De Nederlandsche Bank (DNB) has fined ABN Amro €8.5m ($9.7m) after finding structural shortcomings in its ongoing monitoring of high-risk customers, including a gambler whose transactions were inconsistent with his declared income.
The regulator examined five customer files between September 2023 and September 2024. It concluded that the Dutch bank relied excessively on explanations provided by customers without obtaining sufficient evidence or investigating warning signals.
In the gambling-related case, a customer with a regular income made large cash deposits and withdrawals alongside substantial credit card payments.
The customer claimed that his gambling was funded through loans from his employer, a restaurant and family members, but provided limited supporting documentation.
DNB found that ABN Amro accepted the account without adequately establishing the source of the funds.
The other files covered suspected underground banking, defence-sector brokerage, exports that may have reached Russia through intermediary jurisdictions and opaque transactions involving Gibraltar and high-risk countries.
DNB classified the breach as serious and culpable, although it also considered ABN Amro’s remediation measures and cooperation.
The bank acknowledged the facts and agreed not to challenge the sanction under a simplified settlement, resulting in a 15% reduction from the initial €10m penalty.
The decision places renewed scrutiny on ABN Amro’s financial-crime controls five years after it paid €480m to settle a Dutch criminal investigation into longstanding anti-money laundering failures.
That settlement comprised a €300m fine and €180m in disgorged gains. Prosecutors found deficiencies in customer risk classification, transaction monitoring and the handling of alerts and unusual transactions.
The gambling file also reflects the financial-crime risks surrounding betting activity. Dutch casinos and remote gambling providers are subject to the Money Laundering and Terrorist Financing Prevention Act and must report completed or intended transactions that appear connected to money laundering or terrorist financing.
Casino reporting indicators include cash transactions of €10,000 or more and non-cash payments reaching €15,000.
DNB has separately warned that gambling payment flows carry heightened integrity risks because of transaction volumes, anonymous payment methods and the movement of player deposits and withdrawals.
In February, the Netherlands Gambling Authority ordered Polymarket to withdraw from the Dutch market and threatened weekly penalties over its alleged provision of unlicensed gambling services.
Dutch financial institutions and gambling providers must independently assess unusual activity rather than relying solely on explanations supplied by customers
