The Dutch Financial Intelligence Unit (FIU-Nederland) has expressed concerns over the decision by the country’s main banks to wind down their Anti-Money Laundering (AML) coalition, deeming it “premature.” FIU-Nederland highlighted a practice it referred to as 'CCM,' where criminal cash is used to partially pay staff in labor-intensive sectors such as healthcare, parcel delivery, and construction, through a chain of subcontractors.
“Work that our society partly runs on is paid for with criminal money. A worrying and undermining vulnerability of the financial system,” the organization said. “There are indications that this method leads to labor exploitation. It also encourages unfair competition.”
FIU-Nederland emphasized that the practice of CCM underscores the importance of private banks sharing AML information, as done via Transaction Monitoring Netherlands (TMNL). TMNL is an initiative that facilitates information sharing among large Dutch banks to combat money laundering. It was formed by five of the nation’s biggest lenders – ABN AMRO, ING, Rabobank, Triodos Bank, and De Volksbank.
Earlier this week, TMNL announced that its system is incompatible with the EU’s new Anti-Money Laundering Regulations (AMLR), which will come into effect in 2027. The AMLR will outline the specifics of information sharing across the EU. TMNL stated that due to this incompatibility, the AMLR “largely replaces the Dutch legal initiatives” and it will now “wind down its existing activities.” TMNL plans to reorganize and develop an entirely new business plan.
FIU-Nederland, referencing the Dutch Fiscal Information and Investigation Service (FIOD), said that information sharing and transaction monitoring among multiple bodies are crucial to tackling CCM. “The information that emerges from the interventions initiated will help to identify and combat this form of money laundering. This shows how important it is to combine perspectives,” the organization noted.
“That’s why we regret to read the reports about TMNL. Complex money laundering networks such as the CCM underline the importance of TMNL. The decision-making process seems a bit premature.”
By fLEXI tEAM
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