To fight money laundering and terrorist financing more effectively, banks, the FIU and investigative agencies must better coordinate their priorities and efforts. For this reason, the parties involved (including the FIU) have mapped the risks of financial crime through a Threat Assessment. This Threat Assessment should help banks recognize threats.
All in all, 20 threats have been analyzed in detail; these include criminal phenomena such as the drug economy, sanctions evasion, trade-based money laundering and underground banking.
For banks, the Threat Assessment contains valuable information to better focus their efforts on current threats. At the same time, the Threat Assessment also shows where the risks to banks are not identifiable and thus other measures should be taken.
For example, it is obvious that banks should have more visibility into, say, sanctions evasion and concealment of ultimate stakeholders than underground banking.
So as not to make criminals wiser than they are, these analyses remain available only to banks, FIU and investigative agencies.
Through a response, the Dutch Banking Association (1) stresses that public support for money laundering controls by banks is under pressure, because even bona fide customers are too often inconvenienced by customer investigations by banks.
Helène Erftemeijer (anti-money laundering coordinator of the NVB) also sees that banks, investigative services and the Public Prosecution Service need to work more closely together.
"If public parties can tell us who the crooks are and how they operate, then we can do a much more targeted search and we won't have to bother customers as much," Erftemeijer explained. "With this Threat Assessment we are taking an important first step. More where necessary and less where we can through joint focus."
(1) https://banken.nl/bank/nederlandse-vereniging-van-banken
