De Nederlandsche Bank (DNB) imposed an administrative fine of EUR 2.6 million on bunq B.V. for serious deficiencies in its anti-money laundering controls, based on inadequate ongoing monitoring of high-risk customers and their transactions between January 2021 and May 2022. DNB’s review of four high-risk customer files found bunq did not sufficiently follow up transaction monitoring alerts and other signals of irregularities, creating a risk that unusual transactions were not detected or were detected and reported to the Financial Intelligence Unit (FIU-NL) too late. bunq was also unable to demonstrate why transactions with similar characteristics were reported in one instance and not in another. In setting the fine, DNB referenced severe and culpable non-compliance with Section 3(2)(d) of the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), and noted that multiple examinations between 2018 and 2023 had already identified serious Wwft shortcomings and earlier enforcement measures had not led to sustained compliance; bunq’s size, ability to pay and completion of a remedial programme after the most recent examination were taken into account. bunq has lodged an objection against the decision and the objection process is pending, meaning the decision is not yet final.